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 an imported micronutrient preparation was in issue, specifically whether its small phosphorus content gave it the essential character of a fertilizer under CTH 3105. Applying GRI essential-character principles, Chapter 31 notes/explanatory notes, and the CBIC circular, the authority held that the product was a mixture of magnesium, zinc and boron with only minor phosphorus, and the micronutrients-not phosphorus-imparted its essential character. As a micronutrient preparation applied to foliage/soil to aid plant growth, containing fertilizing elements only in small amounts and not as essential constituents, it was excluded from Chapter 31 and classified as "chemical products n.e.s." under CTI 3824 99 90. - AAR
Classification of an imported micronutrient preparation was in issue, specifically whether its small phosphorus content gave it the essential character of a fertilizer under CTH 3105. Applying GRI essential-character principles, Chapter 31 notes/explanatory notes, and the CBIC circular, the authority held that the product was a mixture of magnesium, zinc and boron with only minor phosphorus, and the micronutrients-not phosphorus-imparted its essential character. As a micronutrient preparation applied to foliage/soil to aid plant growth, containing fertilizing elements only in small amounts and not as essential constituents, it was excluded from Chapter 31 and classified as "chemical products n.e.s." under CTI 3824 99 90. - AAR
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