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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The CESTAT allowed the appeal, setting aside the impugned order concerning the classification of imported PVC Resin SP 660 Suspension Grade. The Tribunal held that the goods are correctly classifiable under CTH 3904 2110, not under CTH 3904 1090, applying Rule 3(a) of the General Rules for the Interpretation of Import Tariff Schedule. The decision relied on a prior ruling in a similar matter and accepted the CIPET clarification dated 25.02.2015. Consequently, the denial of benefit under Notification No. 46/2011-Cus dated 01.06.2011 was overturned, affirming the classification and enabling the appellant to claim the appropriate tariff benefit.
The CESTAT allowed the appeal, setting aside the impugned order concerning the classification of imported PVC Resin SP 660 Suspension Grade. The Tribunal held that the goods are correctly classifiable under CTH 3904 2110, not under CTH 3904 1090, applying Rule 3(a) of the General Rules for the Interpretation of Import Tariff Schedule. The decision relied on a prior ruling in a similar matter and accepted the CIPET clarification dated 25.02.2015. Consequently, the denial of benefit under Notification No. 46/2011-Cus dated 01.06.2011 was overturned, affirming the classification and enabling the appellant to claim the appropriate tariff benefit.
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