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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Ultrasonic flow meters intended for liquid applications were examined for classification as flow meters under tariff item 90261010 versus instruments of heading 9032. The goods' essential character and primary function were held to be measurement of liquid flow rate, with communication protocols merely transmitting measured values to third-party systems. Although the meters provide key inputs used in downstream automatic regulation or control, they do not, as imported, perform automatic regulating/controlling functions or include valves, taps, or starting/stopping/operating mechanisms; hence, they are not excluded from heading 9026. The authority left open departmental scrutiny if imported with control components, which could then attract heading 9032. Classification under 90261010 was affirmed - AAR
Ultrasonic flow meters intended for liquid applications were examined for classification as flow meters under tariff item 90261010 versus instruments of heading 9032. The goods' essential character and primary function were held to be measurement of liquid flow rate, with communication protocols merely transmitting measured values to third-party systems. Although the meters provide key inputs used in downstream automatic regulation or control, they do not, as imported, perform automatic regulating/controlling functions or include valves, taps, or starting/stopping/operating mechanisms; hence, they are not excluded from heading 9026. The authority left open departmental scrutiny if imported with control components, which could then attract heading 9032. Classification under 90261010 was affirmed - AAR
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