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 was determined under the General Rules for Interpretation (GRI): the product's chemical composition and constant elemental ratio establish it as a separately chemically defined compound within Chapter 29. The authority analysed Chapter and Section Notes and explanatory material, found the product is a phospholipid (phosphatidylserine) with a glycerophosphate skeleton conjugated to two fatty acids and Lserine, and treated it as falling within the scope of heading 2923 for lecithins and other phosphoaminolipids. Consequent upon that chemical-character analysis, the product was held classifiable under Tariff Item 2923 2090 of the First Schedule to the Customs Tariff Act, 1975.
Classification was determined under the General Rules for Interpretation (GRI): the product's chemical composition and constant elemental ratio establish it as a separately chemically defined compound within Chapter 29. The authority analysed Chapter and Section Notes and explanatory material, found the product is a phospholipid (phosphatidylserine) with a glycerophosphate skeleton conjugated to two fatty acids and Lserine, and treated it as falling within the scope of heading 2923 for lecithins and other phosphoaminolipids. Consequent upon that chemical-character analysis, the product was held classifiable under Tariff Item 2923 2090 of the First Schedule to the Customs Tariff Act, 1975.
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