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 CESTAT upheld the classification of PP/HDPE/LLDPE bags, sacks, and FIBC under Chapter Headings 54, 63, and 60, rejecting the department's contention for classification under Chapter Heading 39. The Tribunal affirmed the Commissioner (Appeals)'s orders, which were consistent with prior CESTAT decisions and accepted by the department. The Tribunal found no error in the Commissioner's original order dropping the duty demand and noted adherence to judicial discipline in following higher authority rulings. Consequently, the department's appeals were dismissed in their entirety.
The CESTAT upheld the classification of PP/HDPE/LLDPE bags, sacks, and FIBC under Chapter Headings 54, 63, and 60, rejecting the department's contention for classification under Chapter Heading 39. The Tribunal affirmed the Commissioner (Appeals)'s orders, which were consistent with prior CESTAT decisions and accepted by the department. The Tribunal found no error in the Commissioner's original order dropping the duty demand and noted adherence to judicial discipline in following higher authority rulings. Consequently, the department's appeals were dismissed in their entirety.
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