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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Entitlement to exemption under Customs Notification No.31/1997 (DEEC/advance licence) turns on the date of clearance: Sections 15 and 68 of the Customs Act fix the relevant date for duty and tariff valuation as the date a bill of entry for home consumption is presented and identify clearance from warehouse as the operative event. General Exemption No.84-I conditions exemption on production of the licence and certificate at clearance. Because the advance licence had expired by the date of clearance, the exemption ceased and the High Court's rejection of the claim was upheld by the SC.
Entitlement to exemption under Customs Notification No.31/1997 (DEEC/advance licence) turns on the date of clearance: Sections 15 and 68 of the Customs Act fix the relevant date for duty and tariff valuation as the date a bill of entry for home consumption is presented and identify clearance from warehouse as the operative event. General Exemption No.84-I conditions exemption on production of the licence and certificate at clearance. Because the advance licence had expired by the date of clearance, the exemption ceased and the High Court's rejection of the claim was upheld by the SC.
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