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 that imported e-bike components without battery pack or electric compressor do not qualify for reduced duty rates (15% or 25%) under S.No. 531A(1)(a) or (b) of Notification No. 50/2017-Cus. The tribunal rejected appellant's claim that goods declared as "E-Bike in CKD Condition" qualified under the notification, as the examination revealed only parts like plastic cover, chassis, disc brake, shocker, front fork, seat, wheel rim, converter, and controller. Since the shipment lacked the battery pack (either disassembled or preassembled), the standard 50% duty rate applied. However, CESTAT remanded the case to the original adjudicating authority to determine whether the goods could be classified under CTH 87141090 as e-bike parts.
CESTAT ruled that imported e-bike components without battery pack or electric compressor do not qualify for reduced duty rates (15% or 25%) under S.No. 531A(1)(a) or (b) of Notification No. 50/2017-Cus. The tribunal rejected appellant's claim that goods declared as "E-Bike in CKD Condition" qualified under the notification, as the examination revealed only parts like plastic cover, chassis, disc brake, shocker, front fork, seat, wheel rim, converter, and controller. Since the shipment lacked the battery pack (either disassembled or preassembled), the standard 50% duty rate applied. However, CESTAT remanded the case to the original adjudicating authority to determine whether the goods could be classified under CTH 87141090 as e-bike parts.
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