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 classification of imported "Nickel Hydroxide Type M5" under customs tariff headings. The tribunal determined that the imported compound was incorrectly classified, finding it a separate chemically defined compound containing Cobalt Hydroxide and graphite, intended for manufacturing Nickel Cadmium Batteries. While dismissing the appeal on classification merits, the tribunal ruled against imposing penalties, determining no malafide intention existed in the tariff classification. The appeal was partly allowed, with the demand limited to the normal limitation period and penalties withdrawn, based on interpretation of Customs Tariff Act and General Rules of Interpretation.
CESTAT adjudicated a dispute involving classification of imported "Nickel Hydroxide Type M5" under customs tariff headings. The tribunal determined that the imported compound was incorrectly classified, finding it a separate chemically defined compound containing Cobalt Hydroxide and graphite, intended for manufacturing Nickel Cadmium Batteries. While dismissing the appeal on classification merits, the tribunal ruled against imposing penalties, determining no malafide intention existed in the tariff classification. The appeal was partly allowed, with the demand limited to the normal limitation period and penalties withdrawn, based on interpretation of Customs Tariff Act and General Rules of Interpretation.
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