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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Imported polyester fabrics were held classifiable under CTI 5903 20 90 as polyurethane laminated textile fabrics, based on CRCL reports showing PU lamination; classifications under CTI 5903 90 90 and CTI 6006 32 00 were incorrect. The Anti Dumping Notification charging duty on PU coated fabrics did not extend to PU laminated goods, so the anti dumping demand was unsustainable. Rejection of transaction value under Valuation Rule 12 and re determination under the sequential valuation provisions (Rules 3-9) was found improvident because no specification mismatch justified rejection. Penalty for short levy for collusion or wilful misstatement was quashed accordingly.
Imported polyester fabrics were held classifiable under CTI 5903 20 90 as polyurethane laminated textile fabrics, based on CRCL reports showing PU lamination; classifications under CTI 5903 90 90 and CTI 6006 32 00 were incorrect. The Anti Dumping Notification charging duty on PU coated fabrics did not extend to PU laminated goods, so the anti dumping demand was unsustainable. Rejection of transaction value under Valuation Rule 12 and re determination under the sequential valuation provisions (Rules 3-9) was found improvident because no specification mismatch justified rejection. Penalty for short levy for collusion or wilful misstatement was quashed accordingly.
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