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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The Central Government has amended the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020 through Notification No. 14/2025-Customs (N.T.), effective upon publication. The amendments primarily replace the term "certificate" with "proof" throughout the rules, including in definitions, documentation requirements, and verification procedures. In Form I, "CoO" has been replaced with "proof of origin." These changes modify how importers must demonstrate preferential tariff claims under trade agreements, broadening terminology to potentially accommodate various forms of origin documentation beyond traditional certificates. The amendment was issued under powers conferred by section 156 read with section 28DA of the Customs Act, 1962.
The Central Government has amended the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020 through Notification No. 14/2025-Customs (N.T.), effective upon publication. The amendments primarily replace the term "certificate" with "proof" throughout the rules, including in definitions, documentation requirements, and verification procedures. In Form I, "CoO" has been replaced with "proof of origin." These changes modify how importers must demonstrate preferential tariff claims under trade agreements, broadening terminology to potentially accommodate various forms of origin documentation beyond traditional certificates. The amendment was issued under powers conferred by section 156 read with section 28DA of the Customs Act, 1962.
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