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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The Commissioner of Customs NS-II, JNCH issued Public Notice No. 44/2025 implementing Export Entry (Post export conversion in relation to instrument-based scheme) Regulations, 2025, superseding the 2022 regulations. The new regulations establish electronic processing for post-export amendments under Section 149 of the Customs Act, 1962, requiring Additional or Joint Commissioner approval for sensitive field modifications including port of loading, country of final destination, port of discharge, AD code, invoice value, HS code, goods description, and quantity. A one-year time limit applies for conversion applications from clearance date, with specific transitional provisions for entries cleared before and after implementation dates. Exporters must satisfy prescribed conditions including scheme compliance, benefit reversal, and absence of contraventions, submitting complete applications with supporting documentation to avoid deficiency memos.
The Commissioner of Customs NS-II, JNCH issued Public Notice No. 44/2025 implementing Export Entry (Post export conversion in relation to instrument-based scheme) Regulations, 2025, superseding the 2022 regulations. The new regulations establish electronic processing for post-export amendments under Section 149 of the Customs Act, 1962, requiring Additional or Joint Commissioner approval for sensitive field modifications including port of loading, country of final destination, port of discharge, AD code, invoice value, HS code, goods description, and quantity. A one-year time limit applies for conversion applications from clearance date, with specific transitional provisions for entries cleared before and after implementation dates. Exporters must satisfy prescribed conditions including scheme compliance, benefit reversal, and absence of contraventions, submitting complete applications with supporting documentation to avoid deficiency memos.
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