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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Imported compressors for car air conditioning systems classified under CTH 8414 8011 as gas compressors for air conditioning equipment, not CTH 8415 9000 as parts of air conditioning machines. Classification based on Harmonized System Nomenclature and Explanatory Notes to Section XVI. No estoppel in taxation matters regarding prior classification claims. Predominant use test from Westinghouse case not applicable as it pertained to different Section Note. Revenue failed to establish case, impugned order set aside by Appellate Tribunal, appeal allowed.
Imported compressors for car air conditioning systems classified under CTH 8414 8011 as gas compressors for air conditioning equipment, not CTH 8415 9000 as parts of air conditioning machines. Classification based on Harmonized System Nomenclature and Explanatory Notes to Section XVI. No estoppel in taxation matters regarding prior classification claims. Predominant use test from Westinghouse case not applicable as it pertained to different Section Note. Revenue failed to establish case, impugned order set aside by Appellate Tribunal, appeal allowed.
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