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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CESTAT ruled on classification disputes for various mobile phone components. The Tribunal held that Receivers should be classified under CTH 85177090 as phone parts, not standalone audio equipment under CTH 8518. Microphones were denied exemption under N/N. 57/2017-Cus. Connectors qualified for exemption benefits and were classified under CTH 85369090. Various covers and assemblies (Rear Cover, Front Housing, Camera Lens etc.) were deemed eligible for exemption under N/N. 50/2017 and classified under CTH 85177090 as cellular phone parts. The Tribunal emphasized that parts integral to phone functionality should be classified as phone components rather than standalone devices. Extended period limitations were rejected where genuine interpretative issues existed, restricting demands to normal period with applicable interest.
CESTAT ruled on classification disputes for various mobile phone components. The Tribunal held that Receivers should be classified under CTH 85177090 as phone parts, not standalone audio equipment under CTH 8518. Microphones were denied exemption under N/N. 57/2017-Cus. Connectors qualified for exemption benefits and were classified under CTH 85369090. Various covers and assemblies (Rear Cover, Front Housing, Camera Lens etc.) were deemed eligible for exemption under N/N. 50/2017 and classified under CTH 85177090 as cellular phone parts. The Tribunal emphasized that parts integral to phone functionality should be classified as phone components rather than standalone devices. Extended period limitations were rejected where genuine interpretative issues existed, restricting demands to normal period with applicable interest.
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