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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Climatic test chambers were assessed for classification under the Customs Tariff. As the equipment artificially creates and controls environmental conditions (temperature, humidity, light, vibration, pressure) to observe and quantify changes in physical behaviour and performance without altering chemical composition, it was held to be an apparatus for physical analysis. Applying GIR 1 and the HSN Explanatory Notes, Heading 9027 covering instruments and apparatus for physical or chemical analysis was found applicable; in the absence of a specific sub-heading, the residual entry was attracted. Accordingly, the goods were classified under CTI 90278990. - AAR
Climatic test chambers were assessed for classification under the Customs Tariff. As the equipment artificially creates and controls environmental conditions (temperature, humidity, light, vibration, pressure) to observe and quantify changes in physical behaviour and performance without altering chemical composition, it was held to be an apparatus for physical analysis. Applying GIR 1 and the HSN Explanatory Notes, Heading 9027 covering instruments and apparatus for physical or chemical analysis was found applicable; in the absence of a specific sub-heading, the residual entry was attracted. Accordingly, the goods were classified under CTI 90278990. - AAR
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