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...
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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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AAR held that concessional duty under Entry 527B of Notif. No. 50/2017-Cus is available for lithium-ion cells only when used in manufacture of battery or battery packs for electrically operated or hybrid motor vehicles, subject to strict compliance with the IGCR Rules, 2022. Cells used merely for replacement/repair under defects or warranty do not qualify as manufacture of a new product and are ineligible for exemption. Cells becoming obsolete and sold as scrap, or found defective and not issued to production, are treated as unutilized goods, attracting duty and interest under Rules 10 and 11 or requiring re-export or home clearance on payment of duty, with interest payable from date of import.
AAR held that concessional duty under Entry 527B of Notif. No. 50/2017-Cus is available for lithium-ion cells only when used in manufacture of battery or battery packs for electrically operated or hybrid motor vehicles, subject to strict compliance with the IGCR Rules, 2022. Cells used merely for replacement/repair under defects or warranty do not qualify as manufacture of a new product and are ineligible for exemption. Cells becoming obsolete and sold as scrap, or found defective and not issued to production, are treated as unutilized goods, attracting duty and interest under Rules 10 and 11 or requiring re-export or home clearance on payment of duty, with interest payable from date of import.
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