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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An F-card holder was recognised as entitled to practise before any Customs jurisdiction, and a communication clause restricting practice to a single division was set aside as lacking legal authority; that restriction is therefore invalidated. Deficiencies in the licence application identified by the licensing authority remain unaltered, and the applicant has undertaken to remedy those deficiencies, with resultant administrative compliance required. The matter was disposed and related miscellaneous petitions closed.
An F-card holder was recognised as entitled to practise before any Customs jurisdiction, and a communication clause restricting practice to a single division was set aside as lacking legal authority; that restriction is therefore invalidated. Deficiencies in the licence application identified by the licensing authority remain unaltered, and the applicant has undertaken to remedy those deficiencies, with resultant administrative compliance required. The matter was disposed and related miscellaneous petitions closed.
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