Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Classification of aluminium hollow profiles depends on their objective characteristics, nature and physical attributes when presented for assessment, rather than commercial description or intended downstream use unless the tariff makes end use relevant. Uniform cross-section profiles cut to shorter lengths remain profiles and fall under CTI 76042100, not the residuary heading for other aluminium articles, absent evidence that they constitute complete frames or finished articles. The concessional customs exemption for Solar PV Module manufacture applies where the prescribed import procedure and valid end-use certificates are satisfied; it cannot be denied based on hypothetical alternative uses. The exemption remains available for qualifying bills of entry filed before the amendment took effect.
Classification of aluminium hollow profiles depends on their objective characteristics, nature and physical attributes when presented for assessment, rather than commercial description or intended downstream use unless the tariff makes end use relevant. Uniform cross-section profiles cut to shorter lengths remain profiles and fall under CTI 76042100, not the residuary heading for other aluminium articles, absent evidence that they constitute complete frames or finished articles. The concessional customs exemption for Solar PV Module manufacture applies where the prescribed import procedure and valid end-use certificates are satisfied; it cannot be denied based on hypothetical alternative uses. The exemption remains available for qualifying bills of entry filed before the amendment took effect.
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