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 LED monitor kits, comprising components listed at Sr. Nos. 1-16, 18-21, 24 and 30 of Table-I, are classifiable as complete LED monitors under CTH 8528, specifically CTI 85285200, by application of Rule 2(a) of the General Rules for Interpretation. The Authority found that these components, imported in unassembled form, possess the essential character of finished LED monitors capable of direct connection to, and use with, automatic data processing machines of heading 8471, requiring only assembly. Items at Sr. Nos. 17, 22, 23, 25-29, 31 and 32, being mere packing materials and accessories, were held classifiable under their respective headings in terms of Rule 5(b) GRI.
AAR held that the imported LED monitor kits, comprising components listed at Sr. Nos. 1-16, 18-21, 24 and 30 of Table-I, are classifiable as complete LED monitors under CTH 8528, specifically CTI 85285200, by application of Rule 2(a) of the General Rules for Interpretation. The Authority found that these components, imported in unassembled form, possess the essential character of finished LED monitors capable of direct connection to, and use with, automatic data processing machines of heading 8471, requiring only assembly. Items at Sr. Nos. 17, 22, 23, 25-29, 31 and 32, being mere packing materials and accessories, were held classifiable under their respective headings in terms of Rule 5(b) GRI.
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