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 consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
Imported consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
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