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 imported goods - Low Aromatic White Spirit - The IS specification requires that all the eight parameters have to be satisfied in the case of Kerosene. When only seven parameters have been tested and reported, the department cannot conclude that the goods conform IS : 1459 : 2018 (kerosene) and not IS : 1745 : 2018 LAWS. When the department does not accept the classification declared by the importer and rejects the classification stated in the suppliers’ analysis certificate, the burden lies upon the department to establish the correct classification. - AT
Classification of imported goods - Low Aromatic White Spirit - The IS specification requires that all the eight parameters have to be satisfied in the case of Kerosene. When only seven parameters have been tested and reported, the department cannot conclude that the goods conform IS : 1459 : 2018 (kerosene) and not IS : 1745 : 2018 LAWS. When the department does not accept the classification declared by the importer and rejects the classification stated in the suppliers’ analysis certificate, the burden lies upon the department to establish the correct classification. - AT
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