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 imported racks are classifiable as electrical control apparatus and whether they attract concessional BCD. Applying Note 3 to Section XVI and GRI 3(a), the authority found the racks are composite/multi-functional with the principal function being distribution of electricity; the UPS within is ancillary (providing backup to networking equipment) and does not determine essential character. Explanatory Notes and the boards/panels description show Heading 8537 gives the more specific description than Headings 8504/8517/8543, so the racks are classifiable under 8537 10 90. Consequence: the racks are classed under 8537 10 90 and eligible for the concessional BCD under Notification No.45/2025 (S. No. 281). - AAR
Whether imported racks are classifiable as electrical control apparatus and whether they attract concessional BCD. Applying Note 3 to Section XVI and GRI 3(a), the authority found the racks are composite/multi-functional with the principal function being distribution of electricity; the UPS within is ancillary (providing backup to networking equipment) and does not determine essential character. Explanatory Notes and the boards/panels description show Heading 8537 gives the more specific description than Headings 8504/8517/8543, so the racks are classifiable under 8537 10 90. Consequence: the racks are classed under 8537 10 90 and eligible for the concessional BCD under Notification No.45/2025 (S. No. 281). - AAR
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