Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Entitlement to Notification No.25/1999-Cus depends on tariff classification: the tribunal applied the principal function/essential character test and HSN Explanatory Notes to distinguish relays (Chapter 85.36) from automatic regulators/controllers (Chapter 90.32). It found the devices and imported components are designed for protection and tripping of faulty electrical systems, not for stabilizing or regulating electrical parameters, and therefore the imported items qualify as parts of relays under Sl. No.112 of the Notification; appeals were allowed and the related matter remanded for fresh decision consistent with these findings.
Entitlement to Notification No.25/1999-Cus depends on tariff classification: the tribunal applied the principal function/essential character test and HSN Explanatory Notes to distinguish relays (Chapter 85.36) from automatic regulators/controllers (Chapter 90.32). It found the devices and imported components are designed for protection and tripping of faulty electrical systems, not for stabilizing or regulating electrical parameters, and therefore the imported items qualify as parts of relays under Sl. No.112 of the Notification; appeals were allowed and the related matter remanded for fresh decision consistent with these findings.
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