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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Imported dog and cat feed in 20 kg packs was examined for classification as "dog or cat food, put up for retail sale" under CTI 23091000 versus residual/bulk feed under CTI 23099010. Applying GIR 1 and 6, HSN Explanatory Notes, and the principle generalia specialibus non derogant, the goods were held to be consumer-ready pet food based on their completeness, packaging, and presentation, and not dependent on strict domestic labelling formalities such as MRP. Reliance on excise-related authorities and distinguishable precedents was rejected as inapplicable to customs classification. Consequently, classification under CTI 23091000 was affirmed, and CTI 23099010 was ruled out. - AAR
Imported dog and cat feed in 20 kg packs was examined for classification as "dog or cat food, put up for retail sale" under CTI 23091000 versus residual/bulk feed under CTI 23099010. Applying GIR 1 and 6, HSN Explanatory Notes, and the principle generalia specialibus non derogant, the goods were held to be consumer-ready pet food based on their completeness, packaging, and presentation, and not dependent on strict domestic labelling formalities such as MRP. Reliance on excise-related authorities and distinguishable precedents was rejected as inapplicable to customs classification. Consequently, classification under CTI 23091000 was affirmed, and CTI 23099010 was ruled out. - AAR
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