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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Classification of B-Traxim 2C Mn-220 turned on whether it met Chapter 29's threshold for a separate chemically defined organic compound. The product failed that test because the technical material showed variable composition, different amino-acid ligands and fluctuating molecular parameters, so it was excluded from heading 2922. It was then placed in Heading 2309 because it was engineered, presented and used as a feed-use preparation, with the literature showing premix application and use in animal nutrition. The goods were therefore classifiable under CTI 23099090 as preparations of a kind used in animal feeding.
Classification of B-Traxim 2C Mn-220 turned on whether it met Chapter 29's threshold for a separate chemically defined organic compound. The product failed that test because the technical material showed variable composition, different amino-acid ligands and fluctuating molecular parameters, so it was excluded from heading 2922. It was then placed in Heading 2309 because it was engineered, presented and used as a feed-use preparation, with the literature showing premix application and use in animal nutrition. The goods were therefore classifiable under CTI 23099090 as preparations of a kind used in animal feeding.
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