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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Imported nucleotides/nucleosides (including modified derivatives) in solution were held classifiable under CTH 29349990 rather than CTH 38229090 because they are identifiable single chemically defined organic compounds whose dissolution does not alter essential chemical identity, and Chapter 38 applies residually to mixtures/preparations not classifiable elsewhere; applying GRI 3(a), the heading reflecting intrinsic chemical nature was preferred, with any change in classification operative prospectively. Exemption under Entry 102 of Notification 45/2025-Cus read with Entry 55 of List 3 was denied since the goods, as imported, were neither life-saving drugs/medicines nor diagnostic reagents/test kits and thus failed the strict conditions of the notification. - AAR
Imported nucleotides/nucleosides (including modified derivatives) in solution were held classifiable under CTH 29349990 rather than CTH 38229090 because they are identifiable single chemically defined organic compounds whose dissolution does not alter essential chemical identity, and Chapter 38 applies residually to mixtures/preparations not classifiable elsewhere; applying GRI 3(a), the heading reflecting intrinsic chemical nature was preferred, with any change in classification operative prospectively. Exemption under Entry 102 of Notification 45/2025-Cus read with Entry 55 of List 3 was denied since the goods, as imported, were neither life-saving drugs/medicines nor diagnostic reagents/test kits and thus failed the strict conditions of the notification. - AAR
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