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 AAR determined that imported wired remote controllers for air-conditioning systems are not classifiable as "parts" of air conditioners under Heading 8415 90 00 but as electrical control apparatus under Heading 8537 10 90. Applying Rule 1 of the General Rules for Interpretation and Section XVI Note 2(a), the AAR held that where a part is itself covered by a specific Heading in Chapter 84 or 85, it must be classified there rather than as a generic part. As the controllers satisfy the description of consoles for electric control under Heading 8537, that heading, being more specific, prevails over Heading 8415.
The AAR determined that imported wired remote controllers for air-conditioning systems are not classifiable as "parts" of air conditioners under Heading 8415 90 00 but as electrical control apparatus under Heading 8537 10 90. Applying Rule 1 of the General Rules for Interpretation and Section XVI Note 2(a), the AAR held that where a part is itself covered by a specific Heading in Chapter 84 or 85, it must be classified there rather than as a generic part. As the controllers satisfy the description of consoles for electric control under Heading 8537, that heading, being more specific, prevails over Heading 8415.
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