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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Classification dispute over imported Mukhwas (mouth freshener) centred on application of general rules of interpretation and the essential character test for mixtures. The authority analysed ingredient proportions (sugar-coated fennel ~50%, betel nut ~24%, seeds ~20%, plus sugar and dry coconut) and concluded betel nut is not the predominant or essential constituent. Trade/ commercial description was considered but composition determined classification. As a multi-ingredient food preparation not covered by specific pan masala or betel nut tariff entries, it is classifiable under the residual tariff for other food preparations (miscellaneous), with the ruling kept confidential.
Classification dispute over imported Mukhwas (mouth freshener) centred on application of general rules of interpretation and the essential character test for mixtures. The authority analysed ingredient proportions (sugar-coated fennel ~50%, betel nut ~24%, seeds ~20%, plus sugar and dry coconut) and concluded betel nut is not the predominant or essential constituent. Trade/ commercial description was considered but composition determined classification. As a multi-ingredient food preparation not covered by specific pan masala or betel nut tariff entries, it is classifiable under the residual tariff for other food preparations (miscellaneous), with the ruling kept confidential.
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