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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Eight imported products intended for lithium-ion cell manufacture were classified under the Customs Tariff based on their essential character and HSN explanatory notes: hot-melt adhesive under 3506 91 90 (not 3506 10 00, as not retail-packed); electrolyte mixture under residuary 3824 99 00; graphite powder under 3801 10 00; lithium cobalt oxide under 2825 90 90; carbon black under 2803 00 10; NMP under 2933 79 10; ethylene carbonate under 2920 90 00; and boehmite under 2818 30 00. As all items were inputs/raw materials directly used in lithium-ion cell production, concessional BCD benefit was held available under Sr. No. 523A of Notification 50/2017-Cus and Sr. No. 314 of Notification 45/2025-Cus, subject to IGCR Rules, 2022 and end-use verification, with benefit ceasing after 31.03.2026. - AAR
Eight imported products intended for lithium-ion cell manufacture were classified under the Customs Tariff based on their essential character and HSN explanatory notes: hot-melt adhesive under 3506 91 90 (not 3506 10 00, as not retail-packed); electrolyte mixture under residuary 3824 99 00; graphite powder under 3801 10 00; lithium cobalt oxide under 2825 90 90; carbon black under 2803 00 10; NMP under 2933 79 10; ethylene carbonate under 2920 90 00; and boehmite under 2818 30 00. As all items were inputs/raw materials directly used in lithium-ion cell production, concessional BCD benefit was held available under Sr. No. 523A of Notification 50/2017-Cus and Sr. No. 314 of Notification 45/2025-Cus, subject to IGCR Rules, 2022 and end-use verification, with benefit ceasing after 31.03.2026. - AAR
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