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 SC disposed of the petition regarding classification of bicycle parts, specifically whether Chain Wheel and Free Wheel components qualify for import of CRCA and HR sheets under SION serial nos. C-50 to C-122. The Court noted that the High Court had not addressed the petitioner's principal argument, instead relying on the Canon India Pvt. Ltd. case. Without examining whether this contention was previously raised, the SC granted the petitioner liberty to return to the High Court by filing either a review application or other appropriate application so the High Court could properly consider the specific classification argument regarding bicycle parts.
The SC disposed of the petition regarding classification of bicycle parts, specifically whether Chain Wheel and Free Wheel components qualify for import of CRCA and HR sheets under SION serial nos. C-50 to C-122. The Court noted that the High Court had not addressed the petitioner's principal argument, instead relying on the Canon India Pvt. Ltd. case. Without examining whether this contention was previously raised, the SC granted the petitioner liberty to return to the High Court by filing either a review application or other appropriate application so the High Court could properly consider the specific classification argument regarding bicycle parts.
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