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 imported Cap Sub Assembly for Door Outside Handle. Appellant's goods, declared as door handles in Bills of Entry, were determined classifiable under CTH 87082900 (parts and accessories of bodies) rather than CTH 87089900. Following commercial identity test and HSN guidelines, tribunal found these components were specifically identifiable as door handles, integral to vehicle body per Section XVII Note 3 and HSN Explanatory Note B. Addition of plastic material for affixation did not alter principal use. Rule 2(a) of GIR supported classification as finished door handles despite incomplete state. Differential duty upheld with interest, following Supreme Court's compensatory interest principle in Pratibha Processors case. Appeal dismissed.
CESTAT ruled on classification dispute regarding imported Cap Sub Assembly for Door Outside Handle. Appellant's goods, declared as door handles in Bills of Entry, were determined classifiable under CTH 87082900 (parts and accessories of bodies) rather than CTH 87089900. Following commercial identity test and HSN guidelines, tribunal found these components were specifically identifiable as door handles, integral to vehicle body per Section XVII Note 3 and HSN Explanatory Note B. Addition of plastic material for affixation did not alter principal use. Rule 2(a) of GIR supported classification as finished door handles despite incomplete state. Differential duty upheld with interest, following Supreme Court's compensatory interest principle in Pratibha Processors case. Appeal dismissed.
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