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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A specialised cable-laying vessel, designed and equipped for laying/repairing submarine cables, was held to fall under Heading 8906 and classifiable under CTI 89069000, as it is neither a cargo/passenger vessel nor excluded by any specific heading; classification was determined accordingly. Since the vessel fell under Heading 8906 and was imported for cable-laying operations and not for breaking up, it qualified for full BCD exemption under Sl. No. 555 of Notification No. 50/2017-Cus; exemption was allowed. IGST exemption under Sl. No. 557C was also available for vessels of Chapter 89 imported for cable-laying in Indian Customs waters, as Condition No. 105 was satisfied where purchasers, as IoR for cables/other goods, discharged applicable duties; exemption was allowed subject to strict compliance. - AAR
A specialised cable-laying vessel, designed and equipped for laying/repairing submarine cables, was held to fall under Heading 8906 and classifiable under CTI 89069000, as it is neither a cargo/passenger vessel nor excluded by any specific heading; classification was determined accordingly. Since the vessel fell under Heading 8906 and was imported for cable-laying operations and not for breaking up, it qualified for full BCD exemption under Sl. No. 555 of Notification No. 50/2017-Cus; exemption was allowed. IGST exemption under Sl. No. 557C was also available for vessels of Chapter 89 imported for cable-laying in Indian Customs waters, as Condition No. 105 was satisfied where purchasers, as IoR for cables/other goods, discharged applicable duties; exemption was allowed subject to strict compliance. - AAR
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