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 held that imported printing frame profiles are classifiable under CTI 8443 9990 as parts of screen-printing machinery rather than under CTI 7610 9090 as aluminum structures. Applying General Interpretation Rule 1, the tribunal determined that CTI 7610 9090 is a residual heading covering general aluminum structures but not aluminum parts specifically manufactured for screen-printing machines. The imported goods, manufactured with specific dimensions and profile slopes for screen-printing machinery use, attained essential character as machine parts rather than general aluminum products. The tribunal set aside confiscation, differential duty demand, redemption fine, and penalties imposed on appellants. Appeal allowed.
CESTAT held that imported printing frame profiles are classifiable under CTI 8443 9990 as parts of screen-printing machinery rather than under CTI 7610 9090 as aluminum structures. Applying General Interpretation Rule 1, the tribunal determined that CTI 7610 9090 is a residual heading covering general aluminum structures but not aluminum parts specifically manufactured for screen-printing machines. The imported goods, manufactured with specific dimensions and profile slopes for screen-printing machinery use, attained essential character as machine parts rather than general aluminum products. The tribunal set aside confiscation, differential duty demand, redemption fine, and penalties imposed on appellants. Appeal allowed.
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