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 determined imported components including converter, charging socket, connection box, and other parts for E-Rickshaw assembly were correctly classified under CTH 8703 9000 rather than CTH 8708 9900. Following HSN Explanatory Notes, incomplete/unfinished vehicles are classified as complete vehicles if possessing essential character. The tribunal referenced precedent from Videomax Electronics case where separate component imports were considered collectively. The appellant's claim for benefit under Notification No. 55/2017 was rejected as it wasn't claimed during Bill of Entry filing. The tribunal concluded these components constituted essential E-Rickshaw parts warranting classification under CTH 87039000. Appeal dismissed with differential duty, interest and penalties upheld.
CESTAT determined imported components including converter, charging socket, connection box, and other parts for E-Rickshaw assembly were correctly classified under CTH 8703 9000 rather than CTH 8708 9900. Following HSN Explanatory Notes, incomplete/unfinished vehicles are classified as complete vehicles if possessing essential character. The tribunal referenced precedent from Videomax Electronics case where separate component imports were considered collectively. The appellant's claim for benefit under Notification No. 55/2017 was rejected as it wasn't claimed during Bill of Entry filing. The tribunal concluded these components constituted essential E-Rickshaw parts warranting classification under CTH 87039000. Appeal dismissed with differential duty, interest and penalties upheld.
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