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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The dominant issue was tariff classification of components/materials used in an ultrasonic parking sensor under the Customs Tariff Act, 1975 applying GIR 1, Section XVI Notes 1(a), 2(a) and 2(b), and WCO Explanatory Notes. A rubber de-coupling ring, being a sealing/fitting rubber ring, was preferred to a residual entry and classified under CTI 40169320. Sensor-specific parts satisfying the "sole or principal use" test were treated as parts of Heading 8512 and classified under CTI 85129000 (front cover, aluminium membrane, terminal pin, PCBA, shield cover, sensor housing). A mounted piezoelectric crystal was classified under CTI 85416000. A butyl rubber plug, lacking electrical conducting elements, was classified as vulcanised rubber article under CTI 40169990. Polyurethane resin and PMDI-based hardener in primary form were classified under CTI 39095000 and CTI 39093100, respectively.
The dominant issue was tariff classification of components/materials used in an ultrasonic parking sensor under the Customs Tariff Act, 1975 applying GIR 1, Section XVI Notes 1(a), 2(a) and 2(b), and WCO Explanatory Notes. A rubber de-coupling ring, being a sealing/fitting rubber ring, was preferred to a residual entry and classified under CTI 40169320. Sensor-specific parts satisfying the "sole or principal use" test were treated as parts of Heading 8512 and classified under CTI 85129000 (front cover, aluminium membrane, terminal pin, PCBA, shield cover, sensor housing). A mounted piezoelectric crystal was classified under CTI 85416000. A butyl rubber plug, lacking electrical conducting elements, was classified as vulcanised rubber article under CTI 40169990. Polyurethane resin and PMDI-based hardener in primary form were classified under CTI 39095000 and CTI 39093100, respectively.
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