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...
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Customs exemption under Serial No. 404 read with List 33 covers goods described as equipment or units for specialised offshore and onshore petroleum-operation services, provided they also fall within the specified tariff chapters, headings, sub-headings or tariff items in the main notification table. Conformity with the tariff heading stated in List 33 is not required. A Mono Ethylene Glycol Reclamation Plant falling under Chapter 84 qualified because it was imported by a specified person for petroleum operations and matched the goods description. Regulatory certification and TRU clarification supported coverage. A later specific entry did not displace earlier eligibility under the general entry, and the exemption was treated as beneficial rather than ambiguous.
Customs exemption under Serial No. 404 read with List 33 covers goods described as equipment or units for specialised offshore and onshore petroleum-operation services, provided they also fall within the specified tariff chapters, headings, sub-headings or tariff items in the main notification table. Conformity with the tariff heading stated in List 33 is not required. A Mono Ethylene Glycol Reclamation Plant falling under Chapter 84 qualified because it was imported by a specified person for petroleum operations and matched the goods description. Regulatory certification and TRU clarification supported coverage. A later specific entry did not displace earlier eligibility under the general entry, and the exemption was treated as beneficial rather than ambiguous.
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