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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Clutch Master Cylinder and Concentric Slave Cylinder were examined for classification as linear-acting cylinders under CTH 8412 or as motor vehicle parts under CTH 8708. Applying the functional utility and predominant use test, and recognizing that end-use is a relevant aid in tariff classification, the goods were held to be specifically used as clutch components of motor vehicles, warranting classification as parts of clutches under CTI 87089300. The request to treat the ruling as confidential was rejected because no technical, proprietary, or commercially sensitive information was disclosed and the product details were already available in the public domain. - AAR
Clutch Master Cylinder and Concentric Slave Cylinder were examined for classification as linear-acting cylinders under CTH 8412 or as motor vehicle parts under CTH 8708. Applying the functional utility and predominant use test, and recognizing that end-use is a relevant aid in tariff classification, the goods were held to be specifically used as clutch components of motor vehicles, warranting classification as parts of clutches under CTI 87089300. The request to treat the ruling as confidential was rejected because no technical, proprietary, or commercially sensitive information was disclosed and the product details were already available in the public domain. - AAR
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