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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CESTAT held that synthetic casting tapes are properly classifiable under CTH 30059040 rather than CTH 9021. The Tribunal relied on precedent from Johnson & Johnson case which established that Deltalite Casting Tapes fall under sub-heading 3005.10. The Tribunal determined that the goods were not devices/instruments/appliances that would warrant classification under Heading 90.21. Regarding limitation period, CESTAT upheld the invocation of extended period under Section 28(4) of Customs Act, finding that appellant could not claim ignorance of relevant precedential orders from 1999-2000 when filing Bills of Entry. The appeal was dismissed for lack of merit.
CESTAT held that synthetic casting tapes are properly classifiable under CTH 30059040 rather than CTH 9021. The Tribunal relied on precedent from Johnson & Johnson case which established that Deltalite Casting Tapes fall under sub-heading 3005.10. The Tribunal determined that the goods were not devices/instruments/appliances that would warrant classification under Heading 90.21. Regarding limitation period, CESTAT upheld the invocation of extended period under Section 28(4) of Customs Act, finding that appellant could not claim ignorance of relevant precedential orders from 1999-2000 when filing Bills of Entry. The appeal was dismissed for lack of merit.
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