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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Writ petition seeking provisional release of seized imported multifunctional devices allowed; the court ordered interim release at the admission stage where only a seizure memo exists and proceedings remain before the adjudicating authority. The petitioners must furnish a bank guarantee equal to ten percent of the total imported goods' value as security, and if the goods are provisionally released and subsequently supplied or sold, the petitioners must maintain and provide transaction details and customer information to respondent authorities on request. The petition is disposed of subject to these conditions.
Writ petition seeking provisional release of seized imported multifunctional devices allowed; the court ordered interim release at the admission stage where only a seizure memo exists and proceedings remain before the adjudicating authority. The petitioners must furnish a bank guarantee equal to ten percent of the total imported goods' value as security, and if the goods are provisionally released and subsequently supplied or sold, the petitioners must maintain and provide transaction details and customer information to respondent authorities on request. The petition is disposed of subject to these conditions.
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