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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The dominant issue was whether certain data projectors were classifiable under tariff item 85286200 as projectors capable of directly connecting to, and designed for use with, an automatic data processing (ADP) system, despite having additional HDMI and USB ports. Relying on the technical literature, the product design and connectors compatible with PCs, and applying GIR 1 with the Explanatory Notes to heading 8528, it was held that the presence of additional ports does not alter the essential design and principal use with ADP machines; accordingly, the goods were classified under 85286200. On the linked issue of exemption, since the goods are principally used in an ADP system of heading 8471 and fall under the specified subheadings, the benefit under Serial No. 17 of Notification No. 24/2005-Cus. was allowed - AAR
The dominant issue was whether certain data projectors were classifiable under tariff item 85286200 as projectors capable of directly connecting to, and designed for use with, an automatic data processing (ADP) system, despite having additional HDMI and USB ports. Relying on the technical literature, the product design and connectors compatible with PCs, and applying GIR 1 with the Explanatory Notes to heading 8528, it was held that the presence of additional ports does not alter the essential design and principal use with ADP machines; accordingly, the goods were classified under 85286200. On the linked issue of exemption, since the goods are principally used in an ADP system of heading 8471 and fall under the specified subheadings, the benefit under Serial No. 17 of Notification No. 24/2005-Cus. was allowed - AAR
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