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 "Power Recliner," a metal structural mechanism fitted inside motor vehicle seats to adjust the backrest angle, is classifiable as a part of seats under Heading 9401, not as a motor vehicle part under Heading 8708. Applying the Specific Heading Principle and Note 2 to Section XVII, the authority held that once seats fall under Heading 9401, their parts are excluded from Section XVII, including Heading 8708. As the Power Recliner is solely and principally designed for use within motor vehicle seats, incapable of independent use, it qualifies as a "part" of seats under CTI 9401 99 00.
AAR held that the imported "Power Recliner," a metal structural mechanism fitted inside motor vehicle seats to adjust the backrest angle, is classifiable as a part of seats under Heading 9401, not as a motor vehicle part under Heading 8708. Applying the Specific Heading Principle and Note 2 to Section XVII, the authority held that once seats fall under Heading 9401, their parts are excluded from Section XVII, including Heading 8708. As the Power Recliner is solely and principally designed for use within motor vehicle seats, incapable of independent use, it qualifies as a "part" of seats under CTI 9401 99 00.
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