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 central issue is whether imported knitted girls' slips are classifiable as brassieres (CTH 6212) or as slips/petticoats of man-made fibres (CTH 61081110/62081100). Applying HSN Explanatory Notes and functional/structural tests, the authority found three decisive features-beginning above bust/at waist, shoulder straps, and absence of moulded cups/boning/support structures-establishing they are undergarments for modesty/layering, not body-support garments; consequently they do not fall under Heading 6212. As the goods are knitted man-made fibre slips, Rule 3(a) GRI favours the more specific heading 61081110 over 62081100, so they are classifiable under CTH 61081110. - AAR
The central issue is whether imported knitted girls' slips are classifiable as brassieres (CTH 6212) or as slips/petticoats of man-made fibres (CTH 61081110/62081100). Applying HSN Explanatory Notes and functional/structural tests, the authority found three decisive features-beginning above bust/at waist, shoulder straps, and absence of moulded cups/boning/support structures-establishing they are undergarments for modesty/layering, not body-support garments; consequently they do not fall under Heading 6212. As the goods are knitted man-made fibre slips, Rule 3(a) GRI favours the more specific heading 61081110 over 62081100, so they are classifiable under CTH 61081110. - AAR
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