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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GSM/GPRS (2G), LTE (4G), NR (5G), NB-IOT (Narrowband LTE 4G) and GPS modules raised the issue whether they are classifiable as "parts" under heading 8517, specifically CTI 85177990, or elsewhere. Applying the scope of heading 8517.62 and the Explanatory Notes, the authority held that cellular modems enable connection to wireless networks and perform reception/conversion/transmission of data, with modems expressly covered under CTI 85176230. On sequential application of Section Note 2 to Section XVI, no specific entry in Chapters 84 or 85 specifically covered these modules, excluding Section Note 2(a) application. Consequently, the modules were classified as parts under CTH 8517, specifically CTI 85177990. - AAR
GSM/GPRS (2G), LTE (4G), NR (5G), NB-IOT (Narrowband LTE 4G) and GPS modules raised the issue whether they are classifiable as "parts" under heading 8517, specifically CTI 85177990, or elsewhere. Applying the scope of heading 8517.62 and the Explanatory Notes, the authority held that cellular modems enable connection to wireless networks and perform reception/conversion/transmission of data, with modems expressly covered under CTI 85176230. On sequential application of Section Note 2 to Section XVI, no specific entry in Chapters 84 or 85 specifically covered these modules, excluding Section Note 2(a) application. Consequently, the modules were classified as parts under CTH 8517, specifically CTI 85177990. - AAR
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