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 - Import of ‘Accordion springs’ - The Tribunal rejected the appellant's reliance on expert opinions, stating that classification is a quasi-judicial process and cannot be decided by experts. It emphasized that classification must be based on the common parlance test, considering how the goods are commonly understood and sold. The Tribunal concluded that since the Accordion springs did not fit the descriptions of leaf springs or helical springs, they should be classified under the residual category of "others" under CTI 7320 90 90.
Classification - Import of ‘Accordion springs’ - The Tribunal rejected the appellant's reliance on expert opinions, stating that classification is a quasi-judicial process and cannot be decided by experts. It emphasized that classification must be based on the common parlance test, considering how the goods are commonly understood and sold. The Tribunal concluded that since the Accordion springs did not fit the descriptions of leaf springs or helical springs, they should be classified under the residual category of "others" under CTI 7320 90 90.
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