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 the Fe content in imported iron ore fines (IOF) must be determined based on wet metric tonnage (WMT) rather than dry metric tonnage (DMT), reaffirming the precedent set by a coordinate bench. The court emphasized the principle of judicial discipline requiring adherence to prior decisions of coordinate benches unless a larger bench is constituted. Consequently, the appellant's contention challenging the established method was rejected. The court found no substantial question of law under Section 130 of the Customs Act, 1962, arising from the appeals. Accordingly, the appeals were dismissed, upholding the revenue's position and maintaining uniformity in the legal interpretation concerning customs duty assessment on IOF consignments.
The HC held that the Fe content in imported iron ore fines (IOF) must be determined based on wet metric tonnage (WMT) rather than dry metric tonnage (DMT), reaffirming the precedent set by a coordinate bench. The court emphasized the principle of judicial discipline requiring adherence to prior decisions of coordinate benches unless a larger bench is constituted. Consequently, the appellant's contention challenging the established method was rejected. The court found no substantial question of law under Section 130 of the Customs Act, 1962, arising from the appeals. Accordingly, the appeals were dismissed, upholding the revenue's position and maintaining uniformity in the legal interpretation concerning customs duty assessment on IOF consignments.
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