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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Corn silk extract powder, being a single-plant extract obtained by solvent extraction without further purification or chemical modification and supplied as bulk raw material, was held classifiable as vegetable saps and extracts under Heading 1302, specifically CTI 1302 19 19, consistent with HSN Explanatory Notes; classification under residual Heading 2106 was rejected because it covers formulated food preparations/dietary supplements in measured doses and, under GRI 3(a), a product specifically described in 1302 cannot be shifted to a residuary heading. Since the goods fall under CTSH 1302 19 and are not within the notification's listed exclusions, exemption under Sr. No. 54 of Notification No. 50/2017-Cus was held applicable - AAR
Corn silk extract powder, being a single-plant extract obtained by solvent extraction without further purification or chemical modification and supplied as bulk raw material, was held classifiable as vegetable saps and extracts under Heading 1302, specifically CTI 1302 19 19, consistent with HSN Explanatory Notes; classification under residual Heading 2106 was rejected because it covers formulated food preparations/dietary supplements in measured doses and, under GRI 3(a), a product specifically described in 1302 cannot be shifted to a residuary heading. Since the goods fall under CTSH 1302 19 and are not within the notification's listed exclusions, exemption under Sr. No. 54 of Notification No. 50/2017-Cus was held applicable - AAR
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