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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Insulated Gate Bipolar Transistors (IGBTs) were held classifiable as "transistors" under Customs Tariff Heading 8541, since they are three-terminal semiconductor devices (gate, collector, emitter) that control current flow for switching/amplification, matching the functional and structural definition in the Explanatory Notes. The Explanatory Notes also expressly identify IGBTs as an example of transistors, confirming their inclusion within heading 8541. Consequently, the goods were ruled classifiable under CTI 85412900 (transistors, other than photosensitive transistors-other), and not under any alternative classification. - AAR
Insulated Gate Bipolar Transistors (IGBTs) were held classifiable as "transistors" under Customs Tariff Heading 8541, since they are three-terminal semiconductor devices (gate, collector, emitter) that control current flow for switching/amplification, matching the functional and structural definition in the Explanatory Notes. The Explanatory Notes also expressly identify IGBTs as an example of transistors, confirming their inclusion within heading 8541. Consequently, the goods were ruled classifiable under CTI 85412900 (transistors, other than photosensitive transistors-other), and not under any alternative classification. - AAR
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