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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Latex rubber balloons used for party/festive decoration raised the dominant issue of tariff classification under CTH 4016, 9505, or 9503. Classification under CTH 4016 was rejected because it is a residuary heading for utilitarian vulcanised rubber articles, and HSN Notes and CBIC clarification specifically exclude natural rubber latex toy balloons from that heading, directing them to CTH 9503. Classification under CTH 9505 was also rejected since it covers short-term festive/carnival articles, whereas in trade parlance these goods are commercially identified and marketed as "toy balloons," with amusement as their essential character rather than mere decoration. The goods were held classifiable under CTI 95030020. - AAR
Latex rubber balloons used for party/festive decoration raised the dominant issue of tariff classification under CTH 4016, 9505, or 9503. Classification under CTH 4016 was rejected because it is a residuary heading for utilitarian vulcanised rubber articles, and HSN Notes and CBIC clarification specifically exclude natural rubber latex toy balloons from that heading, directing them to CTH 9503. Classification under CTH 9505 was also rejected since it covers short-term festive/carnival articles, whereas in trade parlance these goods are commercially identified and marketed as "toy balloons," with amusement as their essential character rather than mere decoration. The goods were held classifiable under CTI 95030020. - AAR
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