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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Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
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