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 focused on whether products are Ayurvedic medicaments or cosmetics, applying the twin test of ingredient composition and common parlance together with statutory licensing; Tribunal found ingredients, dosages and drug licences established medicinal character and classified goods under Chapter 30, displacing the cosmetics classification. Liability was tested by manufacturer status under loan licence law: the job worker was held to be the manufacturer and pre-August 2011 demands against the principal were set aside. The appellant qualified for SSI exemption for Sept 2011-Feb 2012 and had paid duty from March 2012 after registration, so no differential duty nor penalties were imposed.
Classification focused on whether products are Ayurvedic medicaments or cosmetics, applying the twin test of ingredient composition and common parlance together with statutory licensing; Tribunal found ingredients, dosages and drug licences established medicinal character and classified goods under Chapter 30, displacing the cosmetics classification. Liability was tested by manufacturer status under loan licence law: the job worker was held to be the manufacturer and pre-August 2011 demands against the principal were set aside. The appellant qualified for SSI exemption for Sept 2011-Feb 2012 and had paid duty from March 2012 after registration, so no differential duty nor penalties were imposed.
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