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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AAR held that cathode-coated foils and anode-coated foils are classifiable as parts of electric accumulators under CTI 8507 90 90 by application of Section Note 2(b) to Section XVI, as they are solely/principally used in lithium-ion cells. The separator (microporous film) was classified under CTI 8507 90 10 as "parts of electric accumulators - accumulator cases made of hard rubber and separators." The LC breaker (cell protection device) was held to be an independent electrical protective apparatus classifiable under CTI 8536 30 00. All four items were held eligible for concessional BCD under Serial No. 314 of N/N. 45/2025-Cus., subject to IGCR, 2022 compliance and end-use verification, up to 31.03.2026.
AAR held that cathode-coated foils and anode-coated foils are classifiable as parts of electric accumulators under CTI 8507 90 90 by application of Section Note 2(b) to Section XVI, as they are solely/principally used in lithium-ion cells. The separator (microporous film) was classified under CTI 8507 90 10 as "parts of electric accumulators - accumulator cases made of hard rubber and separators." The LC breaker (cell protection device) was held to be an independent electrical protective apparatus classifiable under CTI 8536 30 00. All four items were held eligible for concessional BCD under Serial No. 314 of N/N. 45/2025-Cus., subject to IGCR, 2022 compliance and end-use verification, up to 31.03.2026.
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