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 HC held that imported second-hand digital Multi-function Devices (MFDs) qualify as Household Electrical Appliances (HSEs) under the amended Customs Regulations Order (CRO), 2021, exempting them from certain import restrictions. Petitioners demonstrated compliance with the twin criteria-importing fewer than 100 units per model annually and each unit weighing over 80 kgs-supported by a Chartered Engineer's report and prior Telangana HC rulings. Applying the principle of benefit of doubt, the Court found insufficient evidence to rebut the importers' declaration or classify the goods as restricted or contraband. Consequently, the Customs Department was directed to grant provisional release of the MFDs subject to appropriate conditions under the Customs Act, 1962, within four weeks, with liberty to finalize adjudication later. The writ petitions were disposed accordingly.
The HC held that imported second-hand digital Multi-function Devices (MFDs) qualify as Household Electrical Appliances (HSEs) under the amended Customs Regulations Order (CRO), 2021, exempting them from certain import restrictions. Petitioners demonstrated compliance with the twin criteria-importing fewer than 100 units per model annually and each unit weighing over 80 kgs-supported by a Chartered Engineer's report and prior Telangana HC rulings. Applying the principle of benefit of doubt, the Court found insufficient evidence to rebut the importers' declaration or classify the goods as restricted or contraband. Consequently, the Customs Department was directed to grant provisional release of the MFDs subject to appropriate conditions under the Customs Act, 1962, within four weeks, with liberty to finalize adjudication later. The writ petitions were disposed accordingly.
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