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 adjudicated a dispute involving simultaneous utilization of Status Holder Incentive Scheme (SHIS) and Zero Duty Export Promotion Capital Goods (EPCG) scheme under Foreign Trade Policy 2009-2014. The tribunal found that the original authority did not comprehensively consider certain aspects of the DGFT public notice and the contextual circumstances of benefit utilization. Consequently, the tribunal set aside the previous order and remanded the matter to the original authority for de novo adjudication, leaving all substantive issues open for fresh determination with a holistic examination of the policy prescriptions and factual matrix.
CESTAT adjudicated a dispute involving simultaneous utilization of Status Holder Incentive Scheme (SHIS) and Zero Duty Export Promotion Capital Goods (EPCG) scheme under Foreign Trade Policy 2009-2014. The tribunal found that the original authority did not comprehensively consider certain aspects of the DGFT public notice and the contextual circumstances of benefit utilization. Consequently, the tribunal set aside the previous order and remanded the matter to the original authority for de novo adjudication, leaving all substantive issues open for fresh determination with a holistic examination of the policy prescriptions and factual matrix.
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