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 knitted synthetic "lounge sets" comprising a coordinated top and bottom, primarily intended for in-house relaxation and sleep, were held classifiable under the residual expression "pyjamas and similar articles" in CTH 6107 (men) and CTH 6108 (women). The scope of these headings is not confined to expressly listed goods (pyjamas, nightshirts, bathrobes, dressing gowns) but extends to similar in-house wear based on material, design, and intended use, consistent with HSN Explanatory Notes emphasizing primary use. Difference in colour between top and bottom was treated as aesthetic and not a legal bar to classification as a set. Accordingly, classification was determined as Tariff Item 61079990 (men) and 61089210 (women). - AAR
Imported knitted synthetic "lounge sets" comprising a coordinated top and bottom, primarily intended for in-house relaxation and sleep, were held classifiable under the residual expression "pyjamas and similar articles" in CTH 6107 (men) and CTH 6108 (women). The scope of these headings is not confined to expressly listed goods (pyjamas, nightshirts, bathrobes, dressing gowns) but extends to similar in-house wear based on material, design, and intended use, consistent with HSN Explanatory Notes emphasizing primary use. Difference in colour between top and bottom was treated as aesthetic and not a legal bar to classification as a set. Accordingly, classification was determined as Tariff Item 61079990 (men) and 61089210 (women). - AAR
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