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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The article addresses misdeclaration and classification of imported batteries, finding the product description accurate and classification as CTH 85076000/85078000 correct. It reasons that invocation of the extended limitation period requires misdeclaration of description; absent dishonest misdescription or intent to evade duty, extended limitation is inapplicable and penalties imposed under customs penalty provisions cannot be sustained. The piece emphasises that a later departmental reclassification of an import declaration does not itself attract penal consequences where full and correct particulars were furnished.
The article addresses misdeclaration and classification of imported batteries, finding the product description accurate and classification as CTH 85076000/85078000 correct. It reasons that invocation of the extended limitation period requires misdeclaration of description; absent dishonest misdescription or intent to evade duty, extended limitation is inapplicable and penalties imposed under customs penalty provisions cannot be sustained. The piece emphasises that a later departmental reclassification of an import declaration does not itself attract penal consequences where full and correct particulars were furnished.
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