Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Scope of application for advance ruling - Seeking ruling on classification of various items - 16 items grouped under 4 categories - if advance rulings in respect of multiple goods/items/products are sought in one application, then it would be well high impossible to render a ruling within the time prescribed in the statute. I can appreciate that there would be instances where the items/products etc. are so similar that they can be combined in a single application. - Therefore, there is no doubt in my mind that the applicant needs to reapply separately in respect of each of these 16 products with sufficient details to justify compliance of the conditions laid down in the note to chapter 23 of the tariff in respect of the heading 23.09. - AAR
Scope of application for advance ruling - Seeking ruling on classification of various items - 16 items grouped under 4 categories - if advance rulings in respect of multiple goods/items/products are sought in one application, then it would be well high impossible to render a ruling within the time prescribed in the statute. I can appreciate that there would be instances where the items/products etc. are so similar that they can be combined in a single application. - Therefore, there is no doubt in my mind that the applicant needs to reapply separately in respect of each of these 16 products with sufficient details to justify compliance of the conditions laid down in the note to chapter 23 of the tariff in respect of the heading 23.09. - AAR
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