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 for imported aircraft engine stands. The tribunal determined these specialized stands, designed for safe multi-modal transport of aircraft engines with shock attenuation systems, should be classified under CTI 8609 00 00 rather than CTI 8716 39 00. While featuring caster wheels for limited workshop mobility, the essential character derives from the cradle component functioning as a container. CESTAT rejected the narrow interpretation of "container" previously applied, noting CTH 8609's scope includes specially designed transport equipment, including open containers. The tribunal set aside the Principal Commissioner's order, allowing classification under CTI 8609 00 00 based on Rule 3(b) of the GI Rules.
CESTAT ruled on classification dispute for imported aircraft engine stands. The tribunal determined these specialized stands, designed for safe multi-modal transport of aircraft engines with shock attenuation systems, should be classified under CTI 8609 00 00 rather than CTI 8716 39 00. While featuring caster wheels for limited workshop mobility, the essential character derives from the cradle component functioning as a container. CESTAT rejected the narrow interpretation of "container" previously applied, noting CTH 8609's scope includes specially designed transport equipment, including open containers. The tribunal set aside the Principal Commissioner's order, allowing classification under CTI 8609 00 00 based on Rule 3(b) of the GI Rules.
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