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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Marine engine, its spares and marine gear box proposed to be imported for use in fishing vessels were held to be classifiable as parts of vessels of headings 8902/8904/8905/8906/8907, based on technical certification that these goods are indispensable for seaworthy operation and are not suitable for automobile or other industrial use; hence they qualify for the concessional rate linked to end use in fishing vessels. Consequently, import of the marine engine, its spares and marine gear box attracts 5% IGST under Sl. No. 252 of Schedule I of Notification No. 01/2017-IGST (Rate). Advance ruling was declined for locally procured marine gear oil and related spares as they fall outside customs advance ruling scope. - AAR
Marine engine, its spares and marine gear box proposed to be imported for use in fishing vessels were held to be classifiable as parts of vessels of headings 8902/8904/8905/8906/8907, based on technical certification that these goods are indispensable for seaworthy operation and are not suitable for automobile or other industrial use; hence they qualify for the concessional rate linked to end use in fishing vessels. Consequently, import of the marine engine, its spares and marine gear box attracts 5% IGST under Sl. No. 252 of Schedule I of Notification No. 01/2017-IGST (Rate). Advance ruling was declined for locally procured marine gear oil and related spares as they fall outside customs advance ruling scope. - AAR
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