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 an imported enzyme-based animal feed additive should be classified as prepared enzymes under heading 3507 or as preparations of a kind used in animal feeding under heading 2309. Since the product contained xylanase along with substantial carriers (limestone and starch) making it suitable and intended only for animal feed, and was understood in trade/common parlance by its functional utility as an animal feed preparation, it was held to fall within heading 2309 rather than 3507. Accordingly, the goods were classified under CTI 23099090 as "other" preparations used in animal feeding. - AAR
The dominant issue was whether an imported enzyme-based animal feed additive should be classified as prepared enzymes under heading 3507 or as preparations of a kind used in animal feeding under heading 2309. Since the product contained xylanase along with substantial carriers (limestone and starch) making it suitable and intended only for animal feed, and was understood in trade/common parlance by its functional utility as an animal feed preparation, it was held to fall within heading 2309 rather than 3507. Accordingly, the goods were classified under CTI 23099090 as "other" preparations used in animal feeding. - AAR
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