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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Importation of J3 Grade stainless steel is held permissible based on controlling precedents, and reliance on those decisions removes the novelty of the issue as res integra; applying that principle the submission finds that Customs' allegations do not sustain penalties or forfeiture/refund demands, which are set aside with consequential relief. The commentary records that appeals were allowed on this ground and that the matter was decided on merits in favour of the importer, removing regulatory impediment to imports of the specified grade.
Importation of J3 Grade stainless steel is held permissible based on controlling precedents, and reliance on those decisions removes the novelty of the issue as res integra; applying that principle the submission finds that Customs' allegations do not sustain penalties or forfeiture/refund demands, which are set aside with consequential relief. The commentary records that appeals were allowed on this ground and that the matter was decided on merits in favour of the importer, removing regulatory impediment to imports of the specified grade.
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