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 goods are classifiable as dried raisins and thereby eligible for notification exemption: applying GRI 1 and Chapter/Heading notes, the Authority finds that goods described as dark seedless raisins retain the essential character of dried grapes and fall within Customs Tariff subheading 08062010 (raisins); outcome - classifiable under CTI 08062010. Eligibility for exemption under Sr. No. 28, Notification No. 45/2025 depends on botanical origin: raisins must be Vitis vinifera (Black Corinth/seedless). Outcome - if importer proves origin via PQ/FSSAI certification and product verification at port, the goods qualify for the specified exemption; otherwise, exemption denied. - AAR
Whether the goods are classifiable as dried raisins and thereby eligible for notification exemption: applying GRI 1 and Chapter/Heading notes, the Authority finds that goods described as dark seedless raisins retain the essential character of dried grapes and fall within Customs Tariff subheading 08062010 (raisins); outcome - classifiable under CTI 08062010. Eligibility for exemption under Sr. No. 28, Notification No. 45/2025 depends on botanical origin: raisins must be Vitis vinifera (Black Corinth/seedless). Outcome - if importer proves origin via PQ/FSSAI certification and product verification at port, the goods qualify for the specified exemption; otherwise, exemption denied. - AAR
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