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 examined whether imported CKD/component kits for Oven Toaster Griller (OTG) appliances constituted incomplete OTGs under Rule 2(a) of the GRI or were classifiable as parts. While the imported components, when assembled, would give the outer shape of an OTG and were dedicated to OTG use, crucial operational elements, notably the tempered front glass door assembly and power cord/plug, were absent from the consignment. Without the glass door, the heating chamber could not retain heat or perform core OTG functions. AAR held that the goods lacked the essential character of complete OTGs and ruled that they fall under Heading 8516, specifically CTI 8516.90.00 as parts.
AAR examined whether imported CKD/component kits for Oven Toaster Griller (OTG) appliances constituted incomplete OTGs under Rule 2(a) of the GRI or were classifiable as parts. While the imported components, when assembled, would give the outer shape of an OTG and were dedicated to OTG use, crucial operational elements, notably the tempered front glass door assembly and power cord/plug, were absent from the consignment. Without the glass door, the heating chamber could not retain heat or perform core OTG functions. AAR held that the goods lacked the essential character of complete OTGs and ruled that they fall under Heading 8516, specifically CTI 8516.90.00 as parts.
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