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 dispute regarding parts of Self-Loading Concrete Mixtures (SLCM). The appellant, both importer and manufacturer of SLCM, had Central Excise registration under tariff heading 8474. The Tribunal determined that since the main machine (SLCM) was already classified under CETH 8474 by Central Excise authorities, its parts must follow the same classification. Revenue's proposal to classify parts under CTH 8708 was rejected. The decision aligned with previous rulings by Telangana VAT Appellate Tribunal and GST regime classifications. Following established legal principle, when revenue's proposed classification fails, the department's case cannot succeed regardless of assessee's classification accuracy. Appeal disposed, maintaining classification as declared in Bills of Entry.
CESTAT ruled on classification dispute regarding parts of Self-Loading Concrete Mixtures (SLCM). The appellant, both importer and manufacturer of SLCM, had Central Excise registration under tariff heading 8474. The Tribunal determined that since the main machine (SLCM) was already classified under CETH 8474 by Central Excise authorities, its parts must follow the same classification. Revenue's proposal to classify parts under CTH 8708 was rejected. The decision aligned with previous rulings by Telangana VAT Appellate Tribunal and GST regime classifications. Following established legal principle, when revenue's proposed classification fails, the department's case cannot succeed regardless of assessee's classification accuracy. Appeal disposed, maintaining classification as declared in Bills of Entry.
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