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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Flexible Printed Circuit Boards are legally classifiable as printed circuits formed on insulating bases, and therefore fall under Tariff Item 8534 00 00; this classification is supported by the definition of printed circuits excluding active elements and by HSN explanatory notes. The mandatory rule that parts falling within a specific heading of Chapters 8485 must be classified under that heading precludes treating such items as parts of aerials, with the operative effect that classification under 8517 is impermissible. An advance ruling may be issued for ongoing import activities and, where classification is contested, the importer may seek a change of classification on merits without estoppel.
Flexible Printed Circuit Boards are legally classifiable as printed circuits formed on insulating bases, and therefore fall under Tariff Item 8534 00 00; this classification is supported by the definition of printed circuits excluding active elements and by HSN explanatory notes. The mandatory rule that parts falling within a specific heading of Chapters 8485 must be classified under that heading precludes treating such items as parts of aerials, with the operative effect that classification under 8517 is impermissible. An advance ruling may be issued for ongoing import activities and, where classification is contested, the importer may seek a change of classification on merits without estoppel.
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