Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC ruled on customs duty exemption for Lactulose imports, addressing classification under Sr. No. 166(A) versus 166(B) of N/N. 50/2017. The court determined that while duty rates were identical under both classifications, 166(B) required compliance with Customs Rules 2022. Without definitively settling classification, HC directed provisional release under 166(A) subject to bond submission. Customs Department retained authority to issue Show Cause Notice and conduct further proceedings. The Bills of Entry were ordered to be assessed with partial exemption under 166(A), contingent on petitioner furnishing required bond. This interim arrangement preserved department's right to determine final classification while facilitating immediate goods clearance.
HC ruled on customs duty exemption for Lactulose imports, addressing classification under Sr. No. 166(A) versus 166(B) of N/N. 50/2017. The court determined that while duty rates were identical under both classifications, 166(B) required compliance with Customs Rules 2022. Without definitively settling classification, HC directed provisional release under 166(A) subject to bond submission. Customs Department retained authority to issue Show Cause Notice and conduct further proceedings. The Bills of Entry were ordered to be assessed with partial exemption under 166(A), contingent on petitioner furnishing required bond. This interim arrangement preserved department's right to determine final classification while facilitating immediate goods clearance.
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