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 dismissed revenue's appeals regarding Target Plus Scheme (TPS) utilization. The tribunal found that imported plastic granules had a legitimate nexus with ready-made garment exports, as confirmed by DGFT's acceptance of license conditions. The court emphasized that imported goods under TPS must be for actual use by importers or supporting manufacturers. The decision aligned with precedent in similar cases, specifically referencing a prior ruling involving Sunstar Overseas Ltd. The tribunal validated the assessee's compliance with TPS and Foreign Trade Policy (FTP) requirements, consequently rejecting revenue's proposed proceedings and upholding the original license benefits.
CESTAT dismissed revenue's appeals regarding Target Plus Scheme (TPS) utilization. The tribunal found that imported plastic granules had a legitimate nexus with ready-made garment exports, as confirmed by DGFT's acceptance of license conditions. The court emphasized that imported goods under TPS must be for actual use by importers or supporting manufacturers. The decision aligned with precedent in similar cases, specifically referencing a prior ruling involving Sunstar Overseas Ltd. The tribunal validated the assessee's compliance with TPS and Foreign Trade Policy (FTP) requirements, consequently rejecting revenue's proposed proceedings and upholding the original license benefits.
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