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 a stylus pen used with a digitizer screen is classifiable as an ADP machine unit under heading 8471. Applying Chapter Note 6(C), it was held that an X-Y coordinate input unit must be connectable to the CPU (through the digitizer) and capable of delivering data; the stylus pen satisfied these conditions as it interfaces via the screen and provides coordinate data. Technological advancement was treated as relevant to tariff interpretation, consistent with the principle against static construction of tariff terms, and a foreign ruling was considered only for persuasive value. The stylus pen was classified under sub-heading 84716090. - AAR
The dominant issue was whether a stylus pen used with a digitizer screen is classifiable as an ADP machine unit under heading 8471. Applying Chapter Note 6(C), it was held that an X-Y coordinate input unit must be connectable to the CPU (through the digitizer) and capable of delivering data; the stylus pen satisfied these conditions as it interfaces via the screen and provides coordinate data. Technological advancement was treated as relevant to tariff interpretation, consistent with the principle against static construction of tariff terms, and a foreign ruling was considered only for persuasive value. The stylus pen was classified under sub-heading 84716090. - AAR
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