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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Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
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