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 customs valuation dispute involving imported steam coal, comprehensively rejecting the proposed re-determination of transaction value. The Tribunal found the customs authority's attempt to substitute the declared value with an alternative invoice value procedurally improper and lacking statutory foundation. Critically, the proposed valuation modification did not conform to Customs Valuation Rules, particularly Rule 3(1) and Section 14 of the Customs Act, 1962. The Tribunal determined that neither confiscation nor penalties were legally sustainable, as no substantive duty evasion or misdeclaration was established. Consequently, the appeal was dismissed, affirming the original transaction value and invalidating the customs authority's proposed interventions.
CESTAT adjudicated a customs valuation dispute involving imported steam coal, comprehensively rejecting the proposed re-determination of transaction value. The Tribunal found the customs authority's attempt to substitute the declared value with an alternative invoice value procedurally improper and lacking statutory foundation. Critically, the proposed valuation modification did not conform to Customs Valuation Rules, particularly Rule 3(1) and Section 14 of the Customs Act, 1962. The Tribunal determined that neither confiscation nor penalties were legally sustainable, as no substantive duty evasion or misdeclaration was established. Consequently, the appeal was dismissed, affirming the original transaction value and invalidating the customs authority's proposed interventions.
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