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 Thermal Printer Ribbons (TPRs) are not specifically covered under any heading of Chapters 84 or 85 as independent goods, nor do they fall under Heading 9612, which covers inked typewriter or similar ribbons giving impressions by impact. Applying Section Note 2(b) to Section XVI, AAR found that TPRs are parts suitable for use solely/principally with thermal printers, which are classifiable under Heading 8443 as printers connectable to automatic data processing machines. Consequently, TPRs are classifiable as "parts and accessories" of such printers under CTH 8443, sub-heading 8443 99, and more specifically under Tariff Item 8443 99 59 - "Other."
AAR held that Thermal Printer Ribbons (TPRs) are not specifically covered under any heading of Chapters 84 or 85 as independent goods, nor do they fall under Heading 9612, which covers inked typewriter or similar ribbons giving impressions by impact. Applying Section Note 2(b) to Section XVI, AAR found that TPRs are parts suitable for use solely/principally with thermal printers, which are classifiable under Heading 8443 as printers connectable to automatic data processing machines. Consequently, TPRs are classifiable as "parts and accessories" of such printers under CTH 8443, sub-heading 8443 99, and more specifically under Tariff Item 8443 99 59 - "Other."
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