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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Parts of aircraft and helicopters manufactured to customer designs do not qualify as parts of general use and are not excluded by the Notes to Section XVII. Because they are bespoke components and are neither propellers, rotors, nor under carriages, they cannot be classified under the specific headings for those items and therefore fall within the residual tariff item for other parts of aeroplanes, helicopters or unmanned aircraft. The ruling applies precedent treating bespoke aluminium fittings and similar components as parts of aircraft and concludes classification under tariff item 88073000.
Parts of aircraft and helicopters manufactured to customer designs do not qualify as parts of general use and are not excluded by the Notes to Section XVII. Because they are bespoke components and are neither propellers, rotors, nor under carriages, they cannot be classified under the specific headings for those items and therefore fall within the residual tariff item for other parts of aeroplanes, helicopters or unmanned aircraft. The ruling applies precedent treating bespoke aluminium fittings and similar components as parts of aircraft and concludes classification under tariff item 88073000.
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