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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Writ petition disposed of by HC: petitioner permitted conditional re-export of imported goods subject to executing a bond for the total amount of any differential duty finally determined and furnishing a bank guarantee equal to 20% of the redetermined value. On compliance with these conditions, petitioner is directed to reexport the goods within twelve days of satisfying the bond and bank guarantee requirements. The court relied on its established approach permitting conditional release for reexport where adjudication can proceed to a monetary determination, instead of retaining goods in India, and expressly imposed the above safeguards to protect revenue while allowing reexport.
Writ petition disposed of by HC: petitioner permitted conditional re-export of imported goods subject to executing a bond for the total amount of any differential duty finally determined and furnishing a bank guarantee equal to 20% of the redetermined value. On compliance with these conditions, petitioner is directed to reexport the goods within twelve days of satisfying the bond and bank guarantee requirements. The court relied on its established approach permitting conditional release for reexport where adjudication can proceed to a monetary determination, instead of retaining goods in India, and expressly imposed the above safeguards to protect revenue while allowing reexport.
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