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 that imported ATM monitors are classifiable under CTH 8473 as parts of ATMs, not CTH 8528 as general monitors. The tribunal applied Clause 2(b) classification criteria, recognizing these monitors as specifically designed and principally used with ATM machines. Since the monitors are integral parts of ATMs and not excluded under Note 1, they should be classified under the same heading as ATM machinery (CTH 8472). The revenue's attempt to classify them under a residual entry was rejected. The appellate order set aside the previous classification, allowing the appeal and confirming classification under CTH 8473.
CESTAT determined that imported ATM monitors are classifiable under CTH 8473 as parts of ATMs, not CTH 8528 as general monitors. The tribunal applied Clause 2(b) classification criteria, recognizing these monitors as specifically designed and principally used with ATM machines. Since the monitors are integral parts of ATMs and not excluded under Note 1, they should be classified under the same heading as ATM machinery (CTH 8472). The revenue's attempt to classify them under a residual entry was rejected. The appellate order set aside the previous classification, allowing the appeal and confirming classification under CTH 8473.
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