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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Provisional export assessments of iron ore fines were reconsidered because the original contract terms had been amended for variation in Fe content, moisture and related parameters, and the revised unit price was not fully reflected in the initial assessment. The Tribunal noted that the exporter had not realised any amount beyond the BRC figures and directed re-finalisation of the shipping bills in light of the amended contract, addendum and supporting documents. It also held that a consignment containing some lumps within the tolerated limit remained classifiable as fines, so duty could not be enhanced merely on that basis. The appellate order was set aside and the matter remanded for fresh finalisation, with refund to follow if due.
Provisional export assessments of iron ore fines were reconsidered because the original contract terms had been amended for variation in Fe content, moisture and related parameters, and the revised unit price was not fully reflected in the initial assessment. The Tribunal noted that the exporter had not realised any amount beyond the BRC figures and directed re-finalisation of the shipping bills in light of the amended contract, addendum and supporting documents. It also held that a consignment containing some lumps within the tolerated limit remained classifiable as fines, so duty could not be enhanced merely on that basis. The appellate order was set aside and the matter remanded for fresh finalisation, with refund to follow if due.
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