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 granted the writ petition, directing provisional release of the impugned second-hand digital multifunction devices (MFDs) subject to conditions under the Customs Act, 1962. Relying on precedent that MFDs prima facie qualify as highly specialised equipment (HSEs) and are provisionally releasable, the court ordered the Customs authority at Chennai to pass orders for provisional release within four weeks and to release the goods within two weeks after the petitioner fulfils imposed conditions. The HC rejected the respondents' contention that the goods are conclusively restricted or prohibited at the provisional stage. The petition is disposed of.
The HC granted the writ petition, directing provisional release of the impugned second-hand digital multifunction devices (MFDs) subject to conditions under the Customs Act, 1962. Relying on precedent that MFDs prima facie qualify as highly specialised equipment (HSEs) and are provisionally releasable, the court ordered the Customs authority at Chennai to pass orders for provisional release within four weeks and to release the goods within two weeks after the petitioner fulfils imposed conditions. The HC rejected the respondents' contention that the goods are conclusively restricted or prohibited at the provisional stage. The petition is disposed of.
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