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 allowed appeal for re-export of seized goods involving Novaluron, finding the original detention order unsustainable. The Tribunal determined that the importer demonstrated bona fide intent by proactively communicating with the foreign supplier upon goods detention. Since the goods were restricted and lacked mandatory registration under Insecticides Act, re-export was deemed appropriate. The Tribunal specifically directed Customs, Noida to permit unconditional re-export of the consignment, emphasizing that no redemption fine, penalty, or duty was required. The decision underscored the principle of distinguishing between restricted and prohibited goods while protecting potential environmental implications of prolonged detention.
CESTAT allowed appeal for re-export of seized goods involving Novaluron, finding the original detention order unsustainable. The Tribunal determined that the importer demonstrated bona fide intent by proactively communicating with the foreign supplier upon goods detention. Since the goods were restricted and lacked mandatory registration under Insecticides Act, re-export was deemed appropriate. The Tribunal specifically directed Customs, Noida to permit unconditional re-export of the consignment, emphasizing that no redemption fine, penalty, or duty was required. The decision underscored the principle of distinguishing between restricted and prohibited goods while protecting potential environmental implications of prolonged detention.
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