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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Issue concerns classification of carbon pultruded plates and applicability of an exemption notification distinguishing raw carbon fibre from articles of carbon fibre. The analysis finds pultruded plates are resin-impregnated, cured, dimensionally stabilized articles (classified under tariff item 68151900) and thus not raw carbon fibre, so they do not qualify under the notification entry for raw carbon fibre. Applying the principle that a part of a part is a part of the whole, the plates used as spar caps are sub-parts of rotor blades and are inseparable in use; consequently they qualify as parts for rotor blade manufacture and attract the concessional basic customs duty rate under the exemption notification.
Issue concerns classification of carbon pultruded plates and applicability of an exemption notification distinguishing raw carbon fibre from articles of carbon fibre. The analysis finds pultruded plates are resin-impregnated, cured, dimensionally stabilized articles (classified under tariff item 68151900) and thus not raw carbon fibre, so they do not qualify under the notification entry for raw carbon fibre. Applying the principle that a part of a part is a part of the whole, the plates used as spar caps are sub-parts of rotor blades and are inseparable in use; consequently they qualify as parts for rotor blade manufacture and attract the concessional basic customs duty rate under the exemption notification.
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