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 directed Respondent No. 2 to adjudicate the Miscellaneous Application filed by the Petitioner under the Customs Valuation Rules (CVR), 2007, concerning the determination of import values. It was held that disclosure of data is governed by the CVR and relevant judicial precedents. The adjudicating authority must consider the Petitioner's request in accordance with these legal provisions and not leave the application pending. The authority is mandated to hear the Petitioner and pass a reasoned order on the application by 15 September 2025. The petition was accordingly disposed of, with clear instructions for timely adjudication consistent with the CVR framework.
The HC directed Respondent No. 2 to adjudicate the Miscellaneous Application filed by the Petitioner under the Customs Valuation Rules (CVR), 2007, concerning the determination of import values. It was held that disclosure of data is governed by the CVR and relevant judicial precedents. The adjudicating authority must consider the Petitioner's request in accordance with these legal provisions and not leave the application pending. The authority is mandated to hear the Petitioner and pass a reasoned order on the application by 15 September 2025. The petition was accordingly disposed of, with clear instructions for timely adjudication consistent with the CVR framework.
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