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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Classification of imported components for an electric vehicle eAxle turned on the application of Section XVII Notes and GIR 1. The reducer, being suitable for use solely/principally with motor vehicles of Chapter 87 and not integral/internal to the vehicle engine, was held classifiable as a transmission part under CTH 8708, akin to a gear box/differential based on its torque/speed reduction function. Ball bearings and tapered roller bearings were held excluded from Section XVII by Note 2(e) and classifiable irrespective of end-use under CTH 8482, with the relevant subheadings applied by bore diameter. The request to keep the ruling confidential was rejected for lack of specific justification. - AAR
Classification of imported components for an electric vehicle eAxle turned on the application of Section XVII Notes and GIR 1. The reducer, being suitable for use solely/principally with motor vehicles of Chapter 87 and not integral/internal to the vehicle engine, was held classifiable as a transmission part under CTH 8708, akin to a gear box/differential based on its torque/speed reduction function. Ball bearings and tapered roller bearings were held excluded from Section XVII by Note 2(e) and classifiable irrespective of end-use under CTH 8482, with the relevant subheadings applied by bore diameter. The request to keep the ruling confidential was rejected for lack of specific justification. - AAR
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