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 HC dismissed the appeal regarding interpretation of "MIMO and LTE Products" in N/N. 11/2014-Customs. Following precedent established in Commissioner of Customs v. Ingram Micro India Pvt. Ltd., the court affirmed that the phrase "MIMO and LTE Products" in the exclusion clause applies only to products combining both technologies, not to products featuring either technology alone. Consequently, Wireless Access Points employing only MIMO technology without LTE standards remain eligible for Basic Customs Duty exemption. The court determined that since this question of law was previously settled, no further legal questions arose in the present appeal.
The HC dismissed the appeal regarding interpretation of "MIMO and LTE Products" in N/N. 11/2014-Customs. Following precedent established in Commissioner of Customs v. Ingram Micro India Pvt. Ltd., the court affirmed that the phrase "MIMO and LTE Products" in the exclusion clause applies only to products combining both technologies, not to products featuring either technology alone. Consequently, Wireless Access Points employing only MIMO technology without LTE standards remain eligible for Basic Customs Duty exemption. The court determined that since this question of law was previously settled, no further legal questions arose in the present appeal.
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