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 geophysical seismic survey equipment comprising interconnected instrument systems was classified by applying Section XVI Note 4 as a functional unit performing geophysical surveying, warranting classification under CTI 9015 80 30 as "Geophysical instruments"; specified sensing/emission components retained this classification even if imported separately, while the controller, if imported alone, was classifiable as parts under CTI 9015 90 00, and other spares/parts were to be classified per Chapter Notes 1-2 to Chapter 90. Although Chapter 90 goods satisfy the tariff-entry condition under Sr. No. 404 of Notification 50/2017-Cus, exemption was held conditional and available only if the importer proves specified-person/sub-contractor status and furnishes prescribed certifications/documents at import, failing which benefit is denied. - AAR
Imported geophysical seismic survey equipment comprising interconnected instrument systems was classified by applying Section XVI Note 4 as a functional unit performing geophysical surveying, warranting classification under CTI 9015 80 30 as "Geophysical instruments"; specified sensing/emission components retained this classification even if imported separately, while the controller, if imported alone, was classifiable as parts under CTI 9015 90 00, and other spares/parts were to be classified per Chapter Notes 1-2 to Chapter 90. Although Chapter 90 goods satisfy the tariff-entry condition under Sr. No. 404 of Notification 50/2017-Cus, exemption was held conditional and available only if the importer proves specified-person/sub-contractor status and furnishes prescribed certifications/documents at import, failing which benefit is denied. - AAR
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