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 examined the classification of imported One Time Seals with RFID, determining whether they fall under CTI 8523 59 10, as claimed by the appellant, or CTI 8309 90 30. Applying the essential character test, the Tribunal held that despite RFID functionality, the goods are fundamentally security seals rather than data-storage devices. The Revenue's contention that the seals' primary character is that of "seals" was accepted. It was further held that show cause notices under Section 28(1) validly raised reclassification within limitation. The impugned order reclassifying the goods under CTI 8309 90 30 was upheld and the appeal dismissed.
CESTAT examined the classification of imported One Time Seals with RFID, determining whether they fall under CTI 8523 59 10, as claimed by the appellant, or CTI 8309 90 30. Applying the essential character test, the Tribunal held that despite RFID functionality, the goods are fundamentally security seals rather than data-storage devices. The Revenue's contention that the seals' primary character is that of "seals" was accepted. It was further held that show cause notices under Section 28(1) validly raised reclassification within limitation. The impugned order reclassifying the goods under CTI 8309 90 30 was upheld and the appeal dismissed.
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