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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PVC insulated cable fitted with connectors was treated as a specifically covered electric cable under tariff heading 8544 42 20, so its end use in a Driver Monitoring System did not displace the specific entry; on that basis, the claimed customs exemption was available. By contrast, the Driver Monitoring System unit and controller assemblies were not signalling apparatus under heading 8512 because they did not themselves generate the warning output; they only captured and processed data, while the alert was produced through other vehicle components. As they were purpose-built automotive sub-assemblies with no independent Chapter 85 classification, they fell under residual motor vehicle parts heading 8708 99 00, and the exemption claim tied to heading 8512 did not apply.
PVC insulated cable fitted with connectors was treated as a specifically covered electric cable under tariff heading 8544 42 20, so its end use in a Driver Monitoring System did not displace the specific entry; on that basis, the claimed customs exemption was available. By contrast, the Driver Monitoring System unit and controller assemblies were not signalling apparatus under heading 8512 because they did not themselves generate the warning output; they only captured and processed data, while the alert was produced through other vehicle components. As they were purpose-built automotive sub-assemblies with no independent Chapter 85 classification, they fell under residual motor vehicle parts heading 8708 99 00, and the exemption claim tied to heading 8512 did not apply.
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