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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Goods imported for manufacture of a combo power unit classifiable under heading 8504 were examined to determine whether they qualify as "parts" of that machine or require independent classification under their specific tariff headings applying GRI 1 and Note 2(a) to Section XVI. Since each item is covered by a specific heading, Note 2(a) mandated classification in its own heading rather than as parts of the combo unit. Accordingly, copper cables were classified under 8544, capacitors under 8532, ceramic gap pads under 8547, connectors/fuses/relays under 8536, inductors/transformers under 8504, and MOSFETs/transistors under 8541; confidentiality protection was granted. - AAR
Goods imported for manufacture of a combo power unit classifiable under heading 8504 were examined to determine whether they qualify as "parts" of that machine or require independent classification under their specific tariff headings applying GRI 1 and Note 2(a) to Section XVI. Since each item is covered by a specific heading, Note 2(a) mandated classification in its own heading rather than as parts of the combo unit. Accordingly, copper cables were classified under 8544, capacitors under 8532, ceramic gap pads under 8547, connectors/fuses/relays under 8536, inductors/transformers under 8504, and MOSFETs/transistors under 8541; confidentiality protection was granted. - AAR
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