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 whether imported new pneumatic rubber tyres with tread patterns EZ-330, CB919, CB905, and CB332 were classifiable as OTR mining tyres under CTH 4011 80 00 or as tyres for buses/lorries under 4011 20. Applying GIR 1 read with GIR 3(a), the authority relied on the tyres' technical characteristics-high tread depth, low speed indices, high load indices, bar-lug/block tread design, reinforced cut- and abrasion-resistant sidewalls-and corroborative technical catalogue and engineer certification establishing exclusive off-highway mining use. Consequently, classification under 4011 20 was excluded and the tyres were held classifiable under 4011 80 00. - AAR
The dominant issue was whether imported new pneumatic rubber tyres with tread patterns EZ-330, CB919, CB905, and CB332 were classifiable as OTR mining tyres under CTH 4011 80 00 or as tyres for buses/lorries under 4011 20. Applying GIR 1 read with GIR 3(a), the authority relied on the tyres' technical characteristics-high tread depth, low speed indices, high load indices, bar-lug/block tread design, reinforced cut- and abrasion-resistant sidewalls-and corroborative technical catalogue and engineer certification establishing exclusive off-highway mining use. Consequently, classification under 4011 20 was excluded and the tyres were held classifiable under 4011 80 00. - AAR
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