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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Whether roasting plain Rava/Suji constitutes ''manufacture'' was decided by applying the change-in-character, use or marketability test and HSN explanatory notes; the tribunal concluded that single or double roasting only reduces moisture and does not alter the product's character, use or marketability, so no new commodity arises. Consequently the process does not fall within the definition of manufacture under central excise law, and roasted Rava/Suji is not leviable to excise duty. The impugned order was set aside and the appeals allowed with consequential relief.
Whether roasting plain Rava/Suji constitutes ''manufacture'' was decided by applying the change-in-character, use or marketability test and HSN explanatory notes; the tribunal concluded that single or double roasting only reduces moisture and does not alter the product's character, use or marketability, so no new commodity arises. Consequently the process does not fall within the definition of manufacture under central excise law, and roasted Rava/Suji is not leviable to excise duty. The impugned order was set aside and the appeals allowed with consequential relief.
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