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 - Electronic Control Unit (ECU) - The CESTAT concluded that ECUs do not qualify as "Electronic automatic regulators" under Chapter 90 for several reasons: ECUs, while electronic, do not regulate anything by themselves but are components of a larger system (ABS) that performs regulation based on inputs analyzed by the ECU. The primary function of the ECU is data analysis, not direct regulation or control of braking, thus it does not fit the criteria for classification under CTI 9032 89 10. - The Tribunal found that the ECU is an automotive part, used solely with automobiles, fitting the classification under CTI 8708 99 00.
Classification of imported goods - Electronic Control Unit (ECU) - The CESTAT concluded that ECUs do not qualify as "Electronic automatic regulators" under Chapter 90 for several reasons: ECUs, while electronic, do not regulate anything by themselves but are components of a larger system (ABS) that performs regulation based on inputs analyzed by the ECU. The primary function of the ECU is data analysis, not direct regulation or control of braking, thus it does not fit the criteria for classification under CTI 9032 89 10. - The Tribunal found that the ECU is an automotive part, used solely with automobiles, fitting the classification under CTI 8708 99 00.
Note: It is a system-generated summary and is for quick reference only.