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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Declared value could be rejected where the proper officer had reason to doubt its truth or accuracy, and a forged consent letter provided a valid basis for rejection; valuation was then correctly made under the sequential rules using the value of similar Heavy Melting Scrap, and the challenge to valuation failed. A separate summons relating to a different customs broker regulations enquiry was irrelevant because it did not affect the valuation and weighment findings in the impugned orders. A proprietary concern has no separate legal existence from its proprietor, so an independent penalty on the concern could not stand once penalty had been imposed on the proprietor; the separate writ filed in the concern's name was therefore not maintainable.
Declared value could be rejected where the proper officer had reason to doubt its truth or accuracy, and a forged consent letter provided a valid basis for rejection; valuation was then correctly made under the sequential rules using the value of similar Heavy Melting Scrap, and the challenge to valuation failed. A separate summons relating to a different customs broker regulations enquiry was irrelevant because it did not affect the valuation and weighment findings in the impugned orders. A proprietary concern has no separate legal existence from its proprietor, so an independent penalty on the concern could not stand once penalty had been imposed on the proprietor; the separate writ filed in the concern's name was therefore not maintainable.
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