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 and traded goods - clear float glass - The Appellate Authority for Advance Ruling highlighted that the presence of a tin layer is a natural outcome of the float glass manufacturing process and does not equate to an applied absorbent layer intended for specific functionalities like infrared light absorption or enhancing reflective qualities. - AAAR concluded that for a product to be classified under 7005 10 (which pertains to glass having an absorbent, reflecting, or non-reflecting layer), there must be a deliberate application of such a layer, distinguishing it from products falling under 7005 29, classified as "other" non-wired glass without specific functional coatings. - Ultimately, the Authority sided with the AAR's classification of the clear float glass under 7005 2990, underscoring the legislative intent and industry standards which differentiate between naturally occurring tin layers and specifically applied absorbent or reflective coatings.
Classification of imported and traded goods - clear float glass - The Appellate Authority for Advance Ruling highlighted that the presence of a tin layer is a natural outcome of the float glass manufacturing process and does not equate to an applied absorbent layer intended for specific functionalities like infrared light absorption or enhancing reflective qualities. - AAAR concluded that for a product to be classified under 7005 10 (which pertains to glass having an absorbent, reflecting, or non-reflecting layer), there must be a deliberate application of such a layer, distinguishing it from products falling under 7005 29, classified as "other" non-wired glass without specific functional coatings. - Ultimately, the Authority sided with the AAR's classification of the clear float glass under 7005 2990, underscoring the legislative intent and industry standards which differentiate between naturally occurring tin layers and specifically applied absorbent or reflective coatings.
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