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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DGFT has amended Para 10.12(D) of the Handbook of Procedures 2023 to introduce General Authorization for Export after Repair (GAER) for SCOMET items. The amendment allows exporters to re-export imported SCOMET items to related entities and repair supply chain partners after repair in India under a one-time authorization valid for one year, subject to quarterly post-reporting requirements. Key conditions include: no change to original specifications during repair, compliance with Internal Compliance Programme requirements, mandatory AEO certification for certain transfers, and prohibition of exports to UNSC-sanctioned destinations. The revised procedure eliminates the need for separate authorizations for each shipment, streamlining the process for compliant exporters while maintaining export control safeguards.
DGFT has amended Para 10.12(D) of the Handbook of Procedures 2023 to introduce General Authorization for Export after Repair (GAER) for SCOMET items. The amendment allows exporters to re-export imported SCOMET items to related entities and repair supply chain partners after repair in India under a one-time authorization valid for one year, subject to quarterly post-reporting requirements. Key conditions include: no change to original specifications during repair, compliance with Internal Compliance Programme requirements, mandatory AEO certification for certain transfers, and prohibition of exports to UNSC-sanctioned destinations. The revised procedure eliminates the need for separate authorizations for each shipment, streamlining the process for compliant exporters while maintaining export control safeguards.
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