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 dismissed the appellant's appeal, holding that imported glass articles are classifiable under Heading 7018 (subheading 7018 10 20) where they are not pierced. The Tribunal declined to follow an earlier coordinate-bench decision in the appellant's favour, finding the facts, tariff schedule and HSN explanatory notes applicable at the relevant time differed from those in prior pronouncements relied upon by the appellant. Having considered a contrary coordinate-bench decision from Ahmedabad and the change in legal and tariff context, the CESTAT concluded there was no merit in the appeal and affirmed rejection of the appellant's classification claim, dismissing the appeal.
The CESTAT dismissed the appellant's appeal, holding that imported glass articles are classifiable under Heading 7018 (subheading 7018 10 20) where they are not pierced. The Tribunal declined to follow an earlier coordinate-bench decision in the appellant's favour, finding the facts, tariff schedule and HSN explanatory notes applicable at the relevant time differed from those in prior pronouncements relied upon by the appellant. Having considered a contrary coordinate-bench decision from Ahmedabad and the change in legal and tariff context, the CESTAT concluded there was no merit in the appeal and affirmed rejection of the appellant's classification claim, dismissing the appeal.
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