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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Prescribes a uniform, integrated application process for obtaining a private bonded warehouse licence under section 58 and permission for manufacture/other operations under section 65 read with MOOWR, 2019, by adopting a single application form with mandated declarations/undertakings and a consolidated document checklist, thereby standardising approvals and due diligence. Mandates maintenance of prescribed digital records and execution of a general bond satisfying both MOOWR, 2019 and section 59 requirements, enabling audit and duty-risk coverage. Specifies clearance treatment: exports require shipping bill and GST invoice, with no customs duty on imported inputs contained in exported resultant products under section 69; domestic clearances constitute "supply" under GST, require GST invoice and ex-bond Bill of Entry with customs duty payment at the time of supply. Clarifies security-based licensing (not necessarily fully enclosed), permits duty-exempt/nil-duty imports via home-consumption Bill of Entry (not treated as warehoused goods), and allows removal without prior officer permission subject to prescribed documentation and duty payment.
Prescribes a uniform, integrated application process for obtaining a private bonded warehouse licence under section 58 and permission for manufacture/other operations under section 65 read with MOOWR, 2019, by adopting a single application form with mandated declarations/undertakings and a consolidated document checklist, thereby standardising approvals and due diligence. Mandates maintenance of prescribed digital records and execution of a general bond satisfying both MOOWR, 2019 and section 59 requirements, enabling audit and duty-risk coverage. Specifies clearance treatment: exports require shipping bill and GST invoice, with no customs duty on imported inputs contained in exported resultant products under section 69; domestic clearances constitute "supply" under GST, require GST invoice and ex-bond Bill of Entry with customs duty payment at the time of supply. Clarifies security-based licensing (not necessarily fully enclosed), permits duty-exempt/nil-duty imports via home-consumption Bill of Entry (not treated as warehoused goods), and allows removal without prior officer permission subject to prescribed documentation and duty payment.
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