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 roller conveyors and sorter conveyors were classifiable as "parts" under Heading 8431 or as conveyors under Heading 8428. Heading 8431 was held inapplicable because it is confined to parts solely or principally suitable for machinery of Headings 8425-8430, whereas the goods are complete, independently operating mechanical units performing distinct functions of moving and sorting goods. Relying on WCO Explanatory Notes and the interpretative principle that independently functional machinery is classified under the heading describing the machine rather than parts provisions, the goods were held classifiable under CTI 84282019 ("Other conveyors"). - AAR
The dominant issue was whether imported roller conveyors and sorter conveyors were classifiable as "parts" under Heading 8431 or as conveyors under Heading 8428. Heading 8431 was held inapplicable because it is confined to parts solely or principally suitable for machinery of Headings 8425-8430, whereas the goods are complete, independently operating mechanical units performing distinct functions of moving and sorting goods. Relying on WCO Explanatory Notes and the interpretative principle that independently functional machinery is classified under the heading describing the machine rather than parts provisions, the goods were held classifiable under CTI 84282019 ("Other conveyors"). - AAR
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