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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Imported inverter assembly units used in mild hybrid vehicles were held to be "static converters" because they perform DC-AC inversion and AC-DC rectification through semiconductor switching devices with control circuitry, bringing them within HSN Explanatory Notes to heading 8504; they were therefore classified under tariff item 8504 40 90 rather than headings for vehicle parts or ignition/electrical equipment. Consequentially, since 8504 40 90 is covered by S. No. 646 of Notification No. 69/2011-Cus. and the goods were represented to be originating in Japan, the imports were held eligible for 0% basic customs duty subject to satisfaction of Japan CEPA origin conditions and CAROTAR, 2020 requirements. - AAR
Imported inverter assembly units used in mild hybrid vehicles were held to be "static converters" because they perform DC-AC inversion and AC-DC rectification through semiconductor switching devices with control circuitry, bringing them within HSN Explanatory Notes to heading 8504; they were therefore classified under tariff item 8504 40 90 rather than headings for vehicle parts or ignition/electrical equipment. Consequentially, since 8504 40 90 is covered by S. No. 646 of Notification No. 69/2011-Cus. and the goods were represented to be originating in Japan, the imports were held eligible for 0% basic customs duty subject to satisfaction of Japan CEPA origin conditions and CAROTAR, 2020 requirements. - AAR
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