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 spectrum analyser models, equipped with telecom-standard applications (3GPP/LTE/5G NR), cellular band coverage and measurement of ACLR, EVM, phase noise and harmonic distortion, are "specially designed for telecommunications" and therefore classifiable under CTI 9030 40 00 of the First Schedule to the Customs Tariff Act, 1975. Rejecting the Department's plea for classification under the residuary "other" category, AAR applied the principle that a specific tariff entry prevails over a general one and found no evidence that the instruments were merely general-purpose. Classification under CTI 9030 40 00 is subject to verification of design and features at import.
AAR held that the imported spectrum analyser models, equipped with telecom-standard applications (3GPP/LTE/5G NR), cellular band coverage and measurement of ACLR, EVM, phase noise and harmonic distortion, are "specially designed for telecommunications" and therefore classifiable under CTI 9030 40 00 of the First Schedule to the Customs Tariff Act, 1975. Rejecting the Department's plea for classification under the residuary "other" category, AAR applied the principle that a specific tariff entry prevails over a general one and found no evidence that the instruments were merely general-purpose. Classification under CTI 9030 40 00 is subject to verification of design and features at import.
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