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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Non-injurious price in anti-dumping proceedings had to be disclosed with sufficient factual detail before final findings, because the calculation directly affected normal value, injury margin and the recommendation of nil duty. The Tribunal found that the disclosure statement did not explain the methodology or basis of the working, so the exporter could not effectively respond; disclosure after final findings caused prejudice and the nil-duty recommendation was set aside and remitted for fresh determination with reasonable opportunity. On product scope, semi-finished ophthalmic lenses with refractive index above 1.6 were upheld as excluded from the product under consideration because the domestic industry did not actually produce that category and the items were not technically or commercially substitutable.
Non-injurious price in anti-dumping proceedings had to be disclosed with sufficient factual detail before final findings, because the calculation directly affected normal value, injury margin and the recommendation of nil duty. The Tribunal found that the disclosure statement did not explain the methodology or basis of the working, so the exporter could not effectively respond; disclosure after final findings caused prejudice and the nil-duty recommendation was set aside and remitted for fresh determination with reasonable opportunity. On product scope, semi-finished ophthalmic lenses with refractive index above 1.6 were upheld as excluded from the product under consideration because the domestic industry did not actually produce that category and the items were not technically or commercially substitutable.
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