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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Imports of inshell walnuts under DFIA were held eligible for exemption from basic customs duty under Notification No. 25/2023-Cus because the DFIA permitted import of "other confectionary ingredients" including nut and nut products and "dietary fibre" based on input description and group classification; therefore, non-availability of a specific ITC(HS) tariff line in the licence did not bar clearance when the goods otherwise matched the permitted description. Challenge to the advance ruling was rejected since s.28J aims at certainty and facilitation, and appellate scrutiny under s.28KA is narrowly confined to profoundly illegal, arbitrary, or unreasoned rulings; no such infirmity was shown, so the appeal was dismissed. - HC
Imports of inshell walnuts under DFIA were held eligible for exemption from basic customs duty under Notification No. 25/2023-Cus because the DFIA permitted import of "other confectionary ingredients" including nut and nut products and "dietary fibre" based on input description and group classification; therefore, non-availability of a specific ITC(HS) tariff line in the licence did not bar clearance when the goods otherwise matched the permitted description. Challenge to the advance ruling was rejected since s.28J aims at certainty and facilitation, and appellate scrutiny under s.28KA is narrowly confined to profoundly illegal, arbitrary, or unreasoned rulings; no such infirmity was shown, so the appeal was dismissed. - HC
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