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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Classification of imported oven-roasted nuts was determined by applying GRI 1 and 3(a), relevant Chapter Notes, and HSN guidance where tariff terms were unclear. "Oven Roasted Arecanuts" were treated as raw arecanuts based on moisture parameters (10-15%) and absence of "roasting" within Chapter 8 processes, and were classified under CTH 0802 (CTI 08028010/20/30, as applicable), denying classification under CTH 2008. "Oven Roasted Cashew Nuts" were held to be preparations of nuts and classified under CTH 2008 (CTI 20081910). "Oven Roasted Walnuts" and "Oven Roasted Pista Nuts" were likewise classified under CTH 2008 (CTI 20081991). - AAR
Classification of imported oven-roasted nuts was determined by applying GRI 1 and 3(a), relevant Chapter Notes, and HSN guidance where tariff terms were unclear. "Oven Roasted Arecanuts" were treated as raw arecanuts based on moisture parameters (10-15%) and absence of "roasting" within Chapter 8 processes, and were classified under CTH 0802 (CTI 08028010/20/30, as applicable), denying classification under CTH 2008. "Oven Roasted Cashew Nuts" were held to be preparations of nuts and classified under CTH 2008 (CTI 20081910). "Oven Roasted Walnuts" and "Oven Roasted Pista Nuts" were likewise classified under CTH 2008 (CTI 20081991). - AAR
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