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 allowed the appeal by remand in a customs matter involving conversion of shipping bill scheme codes from '00' to '03' under section 149 of the Customs Act, 1962. The appellant sought substitution to claim export obligation fulfillment under Foreign Trade Policy. The Tribunal held that the lower authority erred by anticipating and precluding exercise of power regarding non-compliance with notification requirements. The decision on amendment providing access to export obligation claims must be made independently based on each export's specific facts and available documentation for goods conformity assessment. The impugned order was set aside, directing the proper officer to decide the conversion requests according to enacted law and judicial precedents rather than preemptively denying based on procedural examination levels.
CESTAT allowed the appeal by remand in a customs matter involving conversion of shipping bill scheme codes from '00' to '03' under section 149 of the Customs Act, 1962. The appellant sought substitution to claim export obligation fulfillment under Foreign Trade Policy. The Tribunal held that the lower authority erred by anticipating and precluding exercise of power regarding non-compliance with notification requirements. The decision on amendment providing access to export obligation claims must be made independently based on each export's specific facts and available documentation for goods conformity assessment. The impugned order was set aside, directing the proper officer to decide the conversion requests according to enacted law and judicial precedents rather than preemptively denying based on procedural examination levels.
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