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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Whether clutch master cylinders and concentric slave cylinders are classifiable as linear acting hydraulic cylinders under CTH 8412 was determined by applying the HSN Explanatory Notes and examining functional characteristics. The clutch master cylinder converts mechanical pedal input into hydraulic pressure and merely generates/transmits pressure without converting fluid pressure into mechanical motion; it therefore lacks the essential attributes of a hydraulic cylinder under Heading 8412 and was held not classifiable thereunder. The concentric slave cylinder, though using hydraulic pressure to create linear motion, integrates a clutch-specific release bearing and performs functions beyond a standard hydraulic cylinder, so it was also held not classifiable under Heading 8412. Both items were consequently classified as motor vehicle parts under CTH 8708, specifically CTI 87089300. - AAR
Whether clutch master cylinders and concentric slave cylinders are classifiable as linear acting hydraulic cylinders under CTH 8412 was determined by applying the HSN Explanatory Notes and examining functional characteristics. The clutch master cylinder converts mechanical pedal input into hydraulic pressure and merely generates/transmits pressure without converting fluid pressure into mechanical motion; it therefore lacks the essential attributes of a hydraulic cylinder under Heading 8412 and was held not classifiable thereunder. The concentric slave cylinder, though using hydraulic pressure to create linear motion, integrates a clutch-specific release bearing and performs functions beyond a standard hydraulic cylinder, so it was also held not classifiable under Heading 8412. Both items were consequently classified as motor vehicle parts under CTH 8708, specifically CTI 87089300. - AAR
Note: It is a system-generated summary and is for quick reference only.