Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Rejected damaged paddy is classified under HSN 1006 10 90, not 1006 10 10, as it lacks characteristics of seed quality cereal crop and is unfit for human consumption. The exemption under S.No.70 of N/N. 02/2017-Central Tax (Rate) for rice (other than pre-packaged and labelled) is inapplicable as rejected damaged paddy has lost its food quality and human consumption value, being used for industrial usage or cattle feed. It fails to meet the criteria of being fit for human consumption required for the exemption. Therefore, rejected damaged paddy is taxable and does not qualify for the exemption.
Rejected damaged paddy is classified under HSN 1006 10 90, not 1006 10 10, as it lacks characteristics of seed quality cereal crop and is unfit for human consumption. The exemption under S.No.70 of N/N. 02/2017-Central Tax (Rate) for rice (other than pre-packaged and labelled) is inapplicable as rejected damaged paddy has lost its food quality and human consumption value, being used for industrial usage or cattle feed. It fails to meet the criteria of being fit for human consumption required for the exemption. Therefore, rejected damaged paddy is taxable and does not qualify for the exemption.
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