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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Eligible customs arrear cases must be identified for transfer to the Revenue Recovery Unit only after the prescribed appeal period has expired and no appeal, stay, or other proceedings remain pending before any forum. The order requires forwarding such cases with updated TAR particulars, complete e-Office records, the Order-in-Original, any appellate orders, details of stay applications, and a certificate confirming non-pendency of stay under Section 142(1)(c). Complete proposals are to be processed expeditiously, while deficient files may be returned for rectification. An updated Excel statement of transferred cases must be maintained and reflected in future TAR reports to support timely recovery of Government dues.
Eligible customs arrear cases must be identified for transfer to the Revenue Recovery Unit only after the prescribed appeal period has expired and no appeal, stay, or other proceedings remain pending before any forum. The order requires forwarding such cases with updated TAR particulars, complete e-Office records, the Order-in-Original, any appellate orders, details of stay applications, and a certificate confirming non-pendency of stay under Section 142(1)(c). Complete proposals are to be processed expeditiously, while deficient files may be returned for rectification. An updated Excel statement of transferred cases must be maintained and reflected in future TAR reports to support timely recovery of Government dues.
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