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 of imported Manifold Absolute Pressure and Air Temperature sensors turned on whether they are precision measuring instruments or motor-vehicle parts. The tribunal applied Chapter/Heading explanatory notes and the essential character test, finding the devices precision measuring function decisive and the more specific heading applicable; it followed co-ordinate Bench precedents classifying similar sensors under the measuring-instruments heading and treated an Authority for Advance Rulings decision as persuasive. As a result the tribunal set aside the impugned adverse classification order and allowed the appeal with consequential benefits as per law.
Classification of imported Manifold Absolute Pressure and Air Temperature sensors turned on whether they are precision measuring instruments or motor-vehicle parts. The tribunal applied Chapter/Heading explanatory notes and the essential character test, finding the devices precision measuring function decisive and the more specific heading applicable; it followed co-ordinate Bench precedents classifying similar sensors under the measuring-instruments heading and treated an Authority for Advance Rulings decision as persuasive. As a result the tribunal set aside the impugned adverse classification order and allowed the appeal with consequential benefits as per law.
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