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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Central excise valuation rules applied to coal sales: the Tribunal held royalty is includible in transaction value for the normal limitation period though not for the extended period; consequential duty demand on royalty confirmed for the normal period but set aside for extended limitation because there was no intent to evade. Amounts collected as stowing excise duty, forest transit fee, state rural infrastructure and road tax, entry tax, terminal tax, development and environment cess, and duty on captive consumption are characterised as taxes or exempted levies and excluded from assessable value; related penalties and interest were also quashed.
Central excise valuation rules applied to coal sales: the Tribunal held royalty is includible in transaction value for the normal limitation period though not for the extended period; consequential duty demand on royalty confirmed for the normal period but set aside for extended limitation because there was no intent to evade. Amounts collected as stowing excise duty, forest transit fee, state rural infrastructure and road tax, entry tax, terminal tax, development and environment cess, and duty on captive consumption are characterised as taxes or exempted levies and excluded from assessable value; related penalties and interest were also quashed.
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