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 made under the Advance Authorisation scheme were challenged for allegedly failing the pre-import condition and lacking a one-to-one correlation between imported inputs and exported finished goods; the tribunal found no documentary evidence by revenue to prove non-fulfilment and rejected that reasoning, resulting in dismissal of the demand. The tribunal further held that amended provisions enabling imposition of interest, redemption fines and penalties on IGST became effective only from 16.08.2024 and did not apply to the disputed period, rendering interest, redemption fine and penalty unsustainable; accordingly the impugned adjudication was set aside and the appeal allowed.
Imports made under the Advance Authorisation scheme were challenged for allegedly failing the pre-import condition and lacking a one-to-one correlation between imported inputs and exported finished goods; the tribunal found no documentary evidence by revenue to prove non-fulfilment and rejected that reasoning, resulting in dismissal of the demand. The tribunal further held that amended provisions enabling imposition of interest, redemption fines and penalties on IGST became effective only from 16.08.2024 and did not apply to the disputed period, rendering interest, redemption fine and penalty unsustainable; accordingly the impugned adjudication was set aside and the appeal allowed.
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