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 directed that the Respondents decide the Petitioner's exemption application under the 19 Mar 2021 Circular (invoking Regulations 5(2) and 6(1)(o) of the Handling of Cargo in Customs Area Regulations, 2009) expeditiously, preferably within eight weeks of service of the order. Pending that decision, the Respondents were restrained from demanding further cost recovery charges from the Petitioner, a Container Freight Station and custodian under Section 45, for the relevant period. If found eligible, exemption shall be applied retrospectively from the date the application was finally made free of defects. The petition is disposed of.
The HC directed that the Respondents decide the Petitioner's exemption application under the 19 Mar 2021 Circular (invoking Regulations 5(2) and 6(1)(o) of the Handling of Cargo in Customs Area Regulations, 2009) expeditiously, preferably within eight weeks of service of the order. Pending that decision, the Respondents were restrained from demanding further cost recovery charges from the Petitioner, a Container Freight Station and custodian under Section 45, for the relevant period. If found eligible, exemption shall be applied retrospectively from the date the application was finally made free of defects. The petition is disposed of.
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