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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Vehicle Control Unit/Powertrain Control Unit for electric vehicles was examined for tariff classification among CTH 8537, 8543, 9032, and 8708/8714. Heading 8543 was rejected because the unit is not a standalone apparatus with an individual function and, under HSN Explanatory Notes, parts of machinery are excluded and classifiable as parts; hence it could not be treated as an independent electrical apparatus. Heading 9032 was also rejected because the unit neither measures parameters nor independently regulates/controls within the meaning of automatic regulating instruments under HSN criteria, but only processes sensor inputs and sends signals as part of the drivetrain; accordingly, it was held classifiable as vehicle parts under CTH 8708 (three-/four-wheelers) or CTH 8714 (two-wheelers). - AAR
Vehicle Control Unit/Powertrain Control Unit for electric vehicles was examined for tariff classification among CTH 8537, 8543, 9032, and 8708/8714. Heading 8543 was rejected because the unit is not a standalone apparatus with an individual function and, under HSN Explanatory Notes, parts of machinery are excluded and classifiable as parts; hence it could not be treated as an independent electrical apparatus. Heading 9032 was also rejected because the unit neither measures parameters nor independently regulates/controls within the meaning of automatic regulating instruments under HSN criteria, but only processes sensor inputs and sends signals as part of the drivetrain; accordingly, it was held classifiable as vehicle parts under CTH 8708 (three-/four-wheelers) or CTH 8714 (two-wheelers). - AAR
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