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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Ornamental bird feathers proposed to be imported after washing, steam-drying, and dyeing raised the issue whether they fall under Heading 0505 (raw feathers) or Heading 6701 (prepared feathers). Relying on GRI 1, relevant Chapter Notes, and persuasive HSN Explanatory Notes, the authority held that dyeing is a "working" process specifically taking feathers out of Heading 0505, which is limited to simple cleaning, disinfection, or preservation, and placing them under Heading 6701. As the feathers were prepared for ornamental use rather than stuffing, they were classified under CTI 6701 00 90 and not under 0505 10 90. - AAR
Ornamental bird feathers proposed to be imported after washing, steam-drying, and dyeing raised the issue whether they fall under Heading 0505 (raw feathers) or Heading 6701 (prepared feathers). Relying on GRI 1, relevant Chapter Notes, and persuasive HSN Explanatory Notes, the authority held that dyeing is a "working" process specifically taking feathers out of Heading 0505, which is limited to simple cleaning, disinfection, or preservation, and placing them under Heading 6701. As the feathers were prepared for ornamental use rather than stuffing, they were classified under CTI 6701 00 90 and not under 0505 10 90. - AAR
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