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 and set aside the impugned order, holding that the imported items are properly classifiable as parts and accessories of aircraft under CTH 8803. The Tribunal found that certain components were suitable solely or principally for use with articles of CTH 88, precluding their classification as general-use articles under CTH 73, 76 or 82. The appellant's Bills of Entry accurately described the goods and supported classification under CTH 8803, negating any basis for imposing penalty. Relays in issue were upheld as classifiable under CTH 8608. The Revenue's reliance on Section XVII Note 2 distinctions was rejected.
The CESTAT allowed the appeal and set aside the impugned order, holding that the imported items are properly classifiable as parts and accessories of aircraft under CTH 8803. The Tribunal found that certain components were suitable solely or principally for use with articles of CTH 88, precluding their classification as general-use articles under CTH 73, 76 or 82. The appellant's Bills of Entry accurately described the goods and supported classification under CTH 8803, negating any basis for imposing penalty. Relays in issue were upheld as classifiable under CTH 8608. The Revenue's reliance on Section XVII Note 2 distinctions was rejected.
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