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 primary issue is classification: the product is a processed betel-nut preparation (cleaning, cutting, dehydration, flavoring) meeting Chapter 21's supplementary note defining "betel nut product known as supari"; GIR 3(a) (most specific description) and CBIC guidance support placing it under CTH 2106 90 30 - outcome: classified under 21069030. The secondary issue is entitlement to exemption: Serial No. 39, Table 1, Notification No. 68/2012 covers all Chapter 21 goods (except certain alcoholic compounds); since the product falls under 21069030 it qualifies for the concession under Sr. No. 39. - AAR
The primary issue is classification: the product is a processed betel-nut preparation (cleaning, cutting, dehydration, flavoring) meeting Chapter 21's supplementary note defining "betel nut product known as supari"; GIR 3(a) (most specific description) and CBIC guidance support placing it under CTH 2106 90 30 - outcome: classified under 21069030. The secondary issue is entitlement to exemption: Serial No. 39, Table 1, Notification No. 68/2012 covers all Chapter 21 goods (except certain alcoholic compounds); since the product falls under 21069030 it qualifies for the concession under Sr. No. 39. - AAR
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