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 - Magnetic Iron Centre Copper/Centre Core Assembly - Although it is found that Rule 1 of Interpretation read with Section Note 2 itself resolves the classification dispute, also some other Rules of interpretation are examined to see if they would require a different view to be taken. - Applying Rule 3 (a), it is found that the disputed goods, being child part of spark plugs are a more specific description of part of electro-magnets. Further, applying Rule 3(c), the last of the competing entries would be the correct entry. Thus, viewing from any angle, it is found that the disputed goods have been correctly classified in the impugned order under 8511 90 00 as parts of spark plugs. - AT
Classification of imported goods - Magnetic Iron Centre Copper/Centre Core Assembly - Although it is found that Rule 1 of Interpretation read with Section Note 2 itself resolves the classification dispute, also some other Rules of interpretation are examined to see if they would require a different view to be taken. - Applying Rule 3 (a), it is found that the disputed goods, being child part of spark plugs are a more specific description of part of electro-magnets. Further, applying Rule 3(c), the last of the competing entries would be the correct entry. Thus, viewing from any angle, it is found that the disputed goods have been correctly classified in the impugned order under 8511 90 00 as parts of spark plugs. - AT
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