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 polyester filament in cut lengths intended for making paint brushes cannot be classified as synthetic or artificial filament yarn under CTH 54041990 eligible for 12% IGST rate. The key distinction is that filaments tend to break when exposed to high heat or pressure, while yarns, being multi-ply constructions, are more resistant. The imported goods, being monofilaments in cut lengths meant for paint brushes, do not qualify as yarn and are rightly denied the 12% IGST rate benefit under Notification No. 35/2017. They are liable for 18% IGST rate as other goods under CTH 5402-5406. The appeal against denying the 12% IGST rate is dismissed.
Imported polyester filament in cut lengths intended for making paint brushes cannot be classified as synthetic or artificial filament yarn under CTH 54041990 eligible for 12% IGST rate. The key distinction is that filaments tend to break when exposed to high heat or pressure, while yarns, being multi-ply constructions, are more resistant. The imported goods, being monofilaments in cut lengths meant for paint brushes, do not qualify as yarn and are rightly denied the 12% IGST rate benefit under Notification No. 35/2017. They are liable for 18% IGST rate as other goods under CTH 5402-5406. The appeal against denying the 12% IGST rate is dismissed.
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