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 the imported product "PONAA MAKKOLLI STRONG RICE BEER" is not "beer made from malt" under CTH 2203, as it is produced from rice using koji and yeast, with no malted grain or malt extract. The authority found that "made from malt" in Heading 2203 is a restrictive, essential condition and that koji cannot be treated as malt, the two processes being biochemically distinct. Applying General Rules for Interpretation (Rules 1, 3(a) and 6), the product was classified as an "other fermented beverage" under CTH 2206 00 00, irrespective of its labeling as beer.
AAR held that the imported product "PONAA MAKKOLLI STRONG RICE BEER" is not "beer made from malt" under CTH 2203, as it is produced from rice using koji and yeast, with no malted grain or malt extract. The authority found that "made from malt" in Heading 2203 is a restrictive, essential condition and that koji cannot be treated as malt, the two processes being biochemically distinct. Applying General Rules for Interpretation (Rules 1, 3(a) and 6), the product was classified as an "other fermented beverage" under CTH 2206 00 00, irrespective of its labeling as beer.
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