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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Thirteen imported items used in a lithium-ion cell production line were assessed for tariff classification and eligibility to concessional duty under a use-based exemption for "parts, sub-parts, inputs or raw materials" for manufacture of lithium-ion cells. Given their functional indispensability in cell manufacturing and the chapter-neutral wording and object of the exemption, they were held squarely covered, applying the principle that strict construction of exemptions must not defeat legislative purpose; benefit was allowed subject to strict IGCR, 2022 compliance and actual end-use in cells under tariff item 8507 60 00. The adhesive tapes were classified under 3919 10 00; polyether-modified polysiloxane under 3910 00 90; POLYSOL LB-150J under 3903 90 90; and PVDF under 3904 69 90 - AAR
Thirteen imported items used in a lithium-ion cell production line were assessed for tariff classification and eligibility to concessional duty under a use-based exemption for "parts, sub-parts, inputs or raw materials" for manufacture of lithium-ion cells. Given their functional indispensability in cell manufacturing and the chapter-neutral wording and object of the exemption, they were held squarely covered, applying the principle that strict construction of exemptions must not defeat legislative purpose; benefit was allowed subject to strict IGCR, 2022 compliance and actual end-use in cells under tariff item 8507 60 00. The adhesive tapes were classified under 3919 10 00; polyether-modified polysiloxane under 3910 00 90; POLYSOL LB-150J under 3903 90 90; and PVDF under 3904 69 90 - AAR
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