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 a substantial question of law arose regarding assessment of Fe content in exported iron ore fines was resolved by treating the dispute as factual. The tribunals consistent precedent and an SKM certificate testing samples on wet metric tonne basis (WMT) governed the Fe percentage, whereas a CRCL report using dry metric tonne basis (DMT) reflected moisture loss over delayed testing. The determination that Fe content on WMT was below the tariff threshold attracted nil export duty under the applicable notification and the concurrent factual findings of the Appellate Authority and CESTAT were affirmed, leading to dismissal of the revenue appeal.
Whether a substantial question of law arose regarding assessment of Fe content in exported iron ore fines was resolved by treating the dispute as factual. The tribunals consistent precedent and an SKM certificate testing samples on wet metric tonne basis (WMT) governed the Fe percentage, whereas a CRCL report using dry metric tonne basis (DMT) reflected moisture loss over delayed testing. The determination that Fe content on WMT was below the tariff threshold attracted nil export duty under the applicable notification and the concurrent factual findings of the Appellate Authority and CESTAT were affirmed, leading to dismissal of the revenue appeal.
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