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 turns on the General Rules for the Interpretation and the essential character test: if products retain the character of plates or sheets of plastics then they fall under heading 3921, and that outcome is applied here. The authority found plain PVC sheets with surface finishes remain sheets and are classifiable under 3921 (outcome: 3921 subheadings specified). The authority examined profiled/interlocking panels and ruled that longitudinal in-line extrusion (tongue-and-groove) is not further working that changes essential character, so decorative removable wall panels likewise classify under 3921 (outcome: specific subheadings for polystyrene, PVC, polyurethane and other plastics), subject to field verification of composition and structure.
Classification turns on the General Rules for the Interpretation and the essential character test: if products retain the character of plates or sheets of plastics then they fall under heading 3921, and that outcome is applied here. The authority found plain PVC sheets with surface finishes remain sheets and are classifiable under 3921 (outcome: 3921 subheadings specified). The authority examined profiled/interlocking panels and ruled that longitudinal in-line extrusion (tongue-and-groove) is not further working that changes essential character, so decorative removable wall panels likewise classify under 3921 (outcome: specific subheadings for polystyrene, PVC, polyurethane and other plastics), subject to field verification of composition and structure.
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