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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Concessional duty under Sl. No. 5D(b) of Notfn. 57/2017-Cus for "inputs and parts for use in manufacture" was held applicable to imported inputs/parts placed in the display assembly manufacturing line even if they are subsequently damaged or scrapped and do not form part of the finished display assembly, since the phrase covers goods used in the manufacturing process and not merely those incorporated in the final product. IGCR provisions on defective/unutilized goods were treated as addressing goods defective at import and not restricting the notification's scope for process scrap. Benefit of exemption was thus allowed for such manufacturing scrap inputs/parts. - AAR
Concessional duty under Sl. No. 5D(b) of Notfn. 57/2017-Cus for "inputs and parts for use in manufacture" was held applicable to imported inputs/parts placed in the display assembly manufacturing line even if they are subsequently damaged or scrapped and do not form part of the finished display assembly, since the phrase covers goods used in the manufacturing process and not merely those incorporated in the final product. IGCR provisions on defective/unutilized goods were treated as addressing goods defective at import and not restricting the notification's scope for process scrap. Benefit of exemption was thus allowed for such manufacturing scrap inputs/parts. - AAR
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