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 an Electric Power Steering (EPS) Electronic Control Unit (ECU) and its parts under the Customs Tariff Headings. It was held that the EPS-ECU acts as the brain of the power steering system, receiving inputs from speed and torque sensors to determine the assistance required for steering. It regulates the voltage provided to the motor from the battery but does not control electrical quantities directly. The EPS-ECU is a part of the power steering system, not an instrument or apparatus, and is not designed for electricity distribution or control. Therefore, the EPS-ECU and its sub-assembly were correctly classified under CTH 8708 94 00 as parts of motor vehicles. Consequently, the parts of the EPS-ECU do not fall under CTH 8543 90 00. The appeal against the impugned order was dismissed by the Appellate Tribunal.
Classification of an Electric Power Steering (EPS) Electronic Control Unit (ECU) and its parts under the Customs Tariff Headings. It was held that the EPS-ECU acts as the brain of the power steering system, receiving inputs from speed and torque sensors to determine the assistance required for steering. It regulates the voltage provided to the motor from the battery but does not control electrical quantities directly. The EPS-ECU is a part of the power steering system, not an instrument or apparatus, and is not designed for electricity distribution or control. Therefore, the EPS-ECU and its sub-assembly were correctly classified under CTH 8708 94 00 as parts of motor vehicles. Consequently, the parts of the EPS-ECU do not fall under CTH 8543 90 00. The appeal against the impugned order was dismissed by the Appellate Tribunal.
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