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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SC held that crude degummed soyabean oil is a manufactured product distinct from its agricultural origin, not an agricultural product. The administrative circular No. 10/2004 cannot legally expand the exclusionary clause of notification No. 53/2003. The manufacturing process transforms soyabean into a new commodity with different characteristics, thereby enabling the appellant to claim duty-free credit entitlement. The court rejected the HC's finding that crude degummed soyabean oil remains an agricultural product, and allowed the appeal, granting the appellant benefits under the original notification.
SC held that crude degummed soyabean oil is a manufactured product distinct from its agricultural origin, not an agricultural product. The administrative circular No. 10/2004 cannot legally expand the exclusionary clause of notification No. 53/2003. The manufacturing process transforms soyabean into a new commodity with different characteristics, thereby enabling the appellant to claim duty-free credit entitlement. The court rejected the HC's finding that crude degummed soyabean oil remains an agricultural product, and allowed the appeal, granting the appellant benefits under the original notification.
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