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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AAR ruled PVC raincoats must be classified under HSN Code 3926 20 (plastic articles) rather than HSN 6201 (textile garments). Despite functioning as apparel, PVC raincoats are primarily composed of polyvinyl chloride, not textile fabric. PVC sheets cannot be considered woven fabric or textile material in common trade practice. Following the principle of generalia specialibus non derogant, the specific composition of the item prevails over its general use as apparel. The ruling confirmed PVC raincoats attract 18% GST under Schedule-III Entry 111 of relevant GST notifications, regardless of price point. The classification is based on material composition rather than utility.
AAR ruled PVC raincoats must be classified under HSN Code 3926 20 (plastic articles) rather than HSN 6201 (textile garments). Despite functioning as apparel, PVC raincoats are primarily composed of polyvinyl chloride, not textile fabric. PVC sheets cannot be considered woven fabric or textile material in common trade practice. Following the principle of generalia specialibus non derogant, the specific composition of the item prevails over its general use as apparel. The ruling confirmed PVC raincoats attract 18% GST under Schedule-III Entry 111 of relevant GST notifications, regardless of price point. The classification is based on material composition rather than utility.
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