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 classification of a zinc oxide-based mixture containing silicones and other additives, intended for UV protection in sunscreen/cosmetic formulations, under Heading 2817 (zinc oxide) or Heading 3304 (cosmetic/skin-care preparations including sunscreen). It was held that Chapter 28 applies to separate chemically defined compounds and permits only limited additives for safety, preservation, or transport; the additional constituents were functional ingredients added for specific cosmetic use, taking the product outside Heading 2817. Applying Chapter Note 3 to Chapter 33, HSN guidance, and GRI 1, the preparation was covered by the specific inclusion of sunscreen/skin-care preparations under Heading 3304 and was classified under CTI 33049990. - AAR
The dominant issue was classification of a zinc oxide-based mixture containing silicones and other additives, intended for UV protection in sunscreen/cosmetic formulations, under Heading 2817 (zinc oxide) or Heading 3304 (cosmetic/skin-care preparations including sunscreen). It was held that Chapter 28 applies to separate chemically defined compounds and permits only limited additives for safety, preservation, or transport; the additional constituents were functional ingredients added for specific cosmetic use, taking the product outside Heading 2817. Applying Chapter Note 3 to Chapter 33, HSN guidance, and GRI 1, the preparation was covered by the specific inclusion of sunscreen/skin-care preparations under Heading 3304 and was classified under CTI 33049990. - AAR
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