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 tariff classification of a self-propelled electrically powered "tactical hauler" and its components under the Customs Tariff. Applying GIR 1 and HSN Explanatory Notes, the vehicle was held to be a self-propelled works truck for short-distance goods transport, not roadworthy and not fitted with lifting/handling equipment, and was therefore classified under CTH 8709. The wireless remote, being radio remote control apparatus, was classified under CTI 85269200, and the remote charger, being a static converter/battery charger, under CTI 85044030. Applying Section Note 2 to Section XVII, ECU assemblies, PCBA, handle, connector, vent, battery clip, and wheels (with/without motor) were classified as parts under CTI 87099000, while plastic covers (CTI 39269099) and general-use screws (CTI 73181900) were excluded from Chapter 87. - AAR
The dominant issue was tariff classification of a self-propelled electrically powered "tactical hauler" and its components under the Customs Tariff. Applying GIR 1 and HSN Explanatory Notes, the vehicle was held to be a self-propelled works truck for short-distance goods transport, not roadworthy and not fitted with lifting/handling equipment, and was therefore classified under CTH 8709. The wireless remote, being radio remote control apparatus, was classified under CTI 85269200, and the remote charger, being a static converter/battery charger, under CTI 85044030. Applying Section Note 2 to Section XVII, ECU assemblies, PCBA, handle, connector, vent, battery clip, and wheels (with/without motor) were classified as parts under CTI 87099000, while plastic covers (CTI 39269099) and general-use screws (CTI 73181900) were excluded from Chapter 87. - AAR
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