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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Whether the imported preparation is classifiable as an animal-feed preparation under heading 2309: the authority held that trade parlance, supplier declaration and product composition establish the product as an animal feed additive/premix used exclusively for feeding; therefore it satisfies the essential character test for heading 2309 and subheading 2309 90. On HSN exclusion of Chapter 35 protein substances, the authority found enzymes present only in minute amounts within a mixture of stabilisers and carriers, so the exclusion does not apply - consequence: classification under 2309 90 90. - AAR
Whether the imported preparation is classifiable as an animal-feed preparation under heading 2309: the authority held that trade parlance, supplier declaration and product composition establish the product as an animal feed additive/premix used exclusively for feeding; therefore it satisfies the essential character test for heading 2309 and subheading 2309 90. On HSN exclusion of Chapter 35 protein substances, the authority found enzymes present only in minute amounts within a mixture of stabilisers and carriers, so the exclusion does not apply - consequence: classification under 2309 90 90. - AAR
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