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 a composite "planter basket with needle-tufted coir liner" turned on application of GIR 3(b) as a composite good, since GIR 2(a) was inapplicable to a complete, assembled product; the essential character was held to be imparted by the iron basket, which is a finished ornamental/utilitarian article rather than a "part of general use" under Section XV notes, resulting in classification under CTH 8306.29.90. Classification of the coir liner when exported separately turned on Section XI Note 7 treating moulded/processed textile articles as "made-up"; the latex-sprayed, needle-felted coir liner, not covered elsewhere, fell under the residual heading for miscellaneous made-up textile articles, resulting in classification under CTH 6307.90.99. - AAR
Classification of a composite "planter basket with needle-tufted coir liner" turned on application of GIR 3(b) as a composite good, since GIR 2(a) was inapplicable to a complete, assembled product; the essential character was held to be imparted by the iron basket, which is a finished ornamental/utilitarian article rather than a "part of general use" under Section XV notes, resulting in classification under CTH 8306.29.90. Classification of the coir liner when exported separately turned on Section XI Note 7 treating moulded/processed textile articles as "made-up"; the latex-sprayed, needle-felted coir liner, not covered elsewhere, fell under the residual heading for miscellaneous made-up textile articles, resulting in classification under CTH 6307.90.99. - AAR
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