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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Classification turned on whether imported boronated calcium nitrate fell within the watersoluble fertilizer exemption under Notification No.12/2012-Cus; the FCO specifications list unfortified calcium nitrate under watersoluble fertilizers and separately list calcium nitrate with boron under Fortified Fertilizers with distinct boron content. The Tribunal applied strict interpretation of the exemption notification and matched the product specification (higher boron content) to the Fortified Fertilizers entry, concluding the exemption for calcium nitrate did not extend to the boronated product; accordingly the revenue denial of the notification benefit was upheld and the appeals dismissed.
Classification turned on whether imported boronated calcium nitrate fell within the watersoluble fertilizer exemption under Notification No.12/2012-Cus; the FCO specifications list unfortified calcium nitrate under watersoluble fertilizers and separately list calcium nitrate with boron under Fortified Fertilizers with distinct boron content. The Tribunal applied strict interpretation of the exemption notification and matched the product specification (higher boron content) to the Fortified Fertilizers entry, concluding the exemption for calcium nitrate did not extend to the boronated product; accordingly the revenue denial of the notification benefit was upheld and the appeals dismissed.
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