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 goods - seat covers - cycle locks - if it appears that items in issue can be/are used both for cycle rickshaw and cycles also, then they will have to be considered as "parts" unless specifically excluded by the statute and the benefit of the rate of tax under Entry-12 will have to be given to the items in question notwithstanding that they may also be used for cycle/bicycle also - It is a well settled proposition of law that the words used in a statue must be understood in the ordinary and popular sense and not in any technical sense. - HC
Classification of goods - seat covers - cycle locks - if it appears that items in issue can be/are used both for cycle rickshaw and cycles also, then they will have to be considered as "parts" unless specifically excluded by the statute and the benefit of the rate of tax under Entry-12 will have to be given to the items in question notwithstanding that they may also be used for cycle/bicycle also - It is a well settled proposition of law that the words used in a statue must be understood in the ordinary and popular sense and not in any technical sense. - HC
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