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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Exemption under Notification No. 50/2017-Cus was denied because the goods were found suitable for use in motor vehicles, and the exclusion clause was read strictly without adding a requirement that the goods be directly fitted into the vehicle. The Tribunal accepted that motors and sensors used solely in manufacture of automotive systems could fall within the exclusion, so the concessional customs duty benefit was unavailable. Classification of pressure transducers/sensors under CTH 90318000 was sustained because the importer had consistently declared that heading and no dispute on classification was raised in the show cause notice for the relevant period. Interest and penalty on the IGST component were set aside as the amended levy applied prospectively from 16.08.2024.
Exemption under Notification No. 50/2017-Cus was denied because the goods were found suitable for use in motor vehicles, and the exclusion clause was read strictly without adding a requirement that the goods be directly fitted into the vehicle. The Tribunal accepted that motors and sensors used solely in manufacture of automotive systems could fall within the exclusion, so the concessional customs duty benefit was unavailable. Classification of pressure transducers/sensors under CTH 90318000 was sustained because the importer had consistently declared that heading and no dispute on classification was raised in the show cause notice for the relevant period. Interest and penalty on the IGST component were set aside as the amended levy applied prospectively from 16.08.2024.
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