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 dispute on plastic wall products turns on whether items are sheets or builders' ware. The authority finds two categories: plain PVC/PS/PU sheets that retain the essential character of plastic plates/sheets, and mouldings/panels with interlocking edges resembling builders' ware. The interlocking tongue-and-groove is an extrusion profile and not "further working"; the panels are decorative, removable wall coverings lacking structural integration. Consequently, the plain and decorative panels are classifiable as plastic sheets under Heading 3921 (with subheadings for styrenic, vinyl chloride and polyurethane sheets), subject to field verification of composition and structure.
Classification dispute on plastic wall products turns on whether items are sheets or builders' ware. The authority finds two categories: plain PVC/PS/PU sheets that retain the essential character of plastic plates/sheets, and mouldings/panels with interlocking edges resembling builders' ware. The interlocking tongue-and-groove is an extrusion profile and not "further working"; the panels are decorative, removable wall coverings lacking structural integration. Consequently, the plain and decorative panels are classifiable as plastic sheets under Heading 3921 (with subheadings for styrenic, vinyl chloride and polyurethane sheets), subject to field verification of composition and structure.
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