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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Interpretation of HSN explanatory notes determined that ethylbenzene is not an isomer of xylene and therefore its weight cannot be aggregated with dimethylbenzenes to meet the 95% threshold for classification under Chapter 29.02; consequence: product properly classifiable under tariff entry 2707 30 00. On limitation and penalty, the appellant's bona fide classification under subheading 29024400 precluded a finding of suppression or intent to evade duty, so invocation of the extended period of limitation was unsustainable while demand for the normal limitation period with interest was confirmed and penalty under section 11AC was set aside.
Interpretation of HSN explanatory notes determined that ethylbenzene is not an isomer of xylene and therefore its weight cannot be aggregated with dimethylbenzenes to meet the 95% threshold for classification under Chapter 29.02; consequence: product properly classifiable under tariff entry 2707 30 00. On limitation and penalty, the appellant's bona fide classification under subheading 29024400 precluded a finding of suppression or intent to evade duty, so invocation of the extended period of limitation was unsustainable while demand for the normal limitation period with interest was confirmed and penalty under section 11AC was set aside.
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