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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Whether provisional release of imported battery-operated massagers could be denied for want of DCGI approval and an EPR registration certificate was examined. Relying on applicable FAQs, the court held that such massagers, being for wellness/soothing and not therapeutic or disease-alleviation use, do not require approval under the Medical Device Rules, 2017; consequently, the objection based on lack of DCGI approval failed. On EPR compliance, the court noted the relevant public notice permitting filing of EPR applications even post-release, and found that this material was suppressed by the department; hence, the continued detention was unwarranted. The review petitions were dismissed. - HC
Whether provisional release of imported battery-operated massagers could be denied for want of DCGI approval and an EPR registration certificate was examined. Relying on applicable FAQs, the court held that such massagers, being for wellness/soothing and not therapeutic or disease-alleviation use, do not require approval under the Medical Device Rules, 2017; consequently, the objection based on lack of DCGI approval failed. On EPR compliance, the court noted the relevant public notice permitting filing of EPR applications even post-release, and found that this material was suppressed by the department; hence, the continued detention was unwarranted. The review petitions were dismissed. - HC
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