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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The dominant issue was classification of an imported wheat seed extract standardized to deliver functional lipids, intended exclusively for use in dietary supplements and licensed as a functional ingredient, as between a plant extract heading and a food preparation heading. Applying the tariff notes and end-use character, it was held that the solvent-extracted, concentrated product was marketed and used as a nutraceutical for general well-being (skin and hair health) and not for treatment or prevention of disease, giving it the essential character of a food preparation under Heading 2106 rather than a mere botanical extract. Accordingly, it was classified under CTH 2106 90 99. - AAR
The dominant issue was classification of an imported wheat seed extract standardized to deliver functional lipids, intended exclusively for use in dietary supplements and licensed as a functional ingredient, as between a plant extract heading and a food preparation heading. Applying the tariff notes and end-use character, it was held that the solvent-extracted, concentrated product was marketed and used as a nutraceutical for general well-being (skin and hair health) and not for treatment or prevention of disease, giving it the essential character of a food preparation under Heading 2106 rather than a mere botanical extract. Accordingly, it was classified under CTH 2106 90 99. - AAR
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