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 implantable intracranial "stent" was classifiable as an "artificial part of the body" under CTI 9021 39 00 or under the residual implanted appliances entry CTI 9021 90 90. Applying the scope of Heading 9021 and the anatomical replacement test, the authority held that the device functions therapeutically as a scaffold to retain embolization coils and achieve occlusion, without replicating or substituting any anatomical vessel or aneurysm wall segment. Since it is not a prosthetic substitute and the competing entries must be compared at the same hierarchical level, classification under "artificial parts" was rejected and the product was classified under CTI 9021 90 90. - AAR
The dominant issue was whether an imported implantable intracranial "stent" was classifiable as an "artificial part of the body" under CTI 9021 39 00 or under the residual implanted appliances entry CTI 9021 90 90. Applying the scope of Heading 9021 and the anatomical replacement test, the authority held that the device functions therapeutically as a scaffold to retain embolization coils and achieve occlusion, without replicating or substituting any anatomical vessel or aneurysm wall segment. Since it is not a prosthetic substitute and the competing entries must be compared at the same hierarchical level, classification under "artificial parts" was rejected and the product was classified under CTI 9021 90 90. - AAR
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