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 goods - agglomerate plastic granules - Despite the apparent conflict between Chapter Note 3 and Notes 6 and 7, the Tribunal referred to the General Notes to Chapter 39 in the Harmonized System of Nomenclature (HSN) to resolve the conflict. - The Tribunal agreed with the appellant's contention that their goods should be classified under headings 3901 to 3914 rather than under heading 39159029. This decision was based on the interpretation of Chapter Notes 6 and 7, which specify that waste, parings, and scrap of a single thermoplastic material transformed into primary forms should be classified under headings 3901 to 3914.
Classification of goods - agglomerate plastic granules - Despite the apparent conflict between Chapter Note 3 and Notes 6 and 7, the Tribunal referred to the General Notes to Chapter 39 in the Harmonized System of Nomenclature (HSN) to resolve the conflict. - The Tribunal agreed with the appellant's contention that their goods should be classified under headings 3901 to 3914 rather than under heading 39159029. This decision was based on the interpretation of Chapter Notes 6 and 7, which specify that waste, parings, and scrap of a single thermoplastic material transformed into primary forms should be classified under headings 3901 to 3914.
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