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 upheld the Commissioner of Customs' order granting Target Plus Scheme (TPS) benefits to the importer. Despite not directly using imported plastic granules in exported products, the tribunal found that TPS is a post-export incentive scheme with limited actual user scope. The tribunal referenced a precedent case involving plastic granules used in packaging, concluding that the importer fulfilled the twin conditions of the scheme. No substantial evidence was presented by the Revenue to challenge the original order, resulting in dismissal of the Revenue's appeal and confirmation of the TPS benefits.
CESTAT upheld the Commissioner of Customs' order granting Target Plus Scheme (TPS) benefits to the importer. Despite not directly using imported plastic granules in exported products, the tribunal found that TPS is a post-export incentive scheme with limited actual user scope. The tribunal referenced a precedent case involving plastic granules used in packaging, concluding that the importer fulfilled the twin conditions of the scheme. No substantial evidence was presented by the Revenue to challenge the original order, resulting in dismissal of the Revenue's appeal and confirmation of the TPS benefits.
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