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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Paddle wheel aerators used in aquaculture do not fall within the specific agricultural machinery heading (HSN 8436) because that entry is limited to machineries used in agriculture, horticulture, forestry, poultry and bee keeping; ejusdem generis and noscitur a sociis principles and the popular meaning of "agriculture" were applied, and notification definitions are confined to their own notifications. A press release is not binding for tariff classification. Absent a specific tariff entry, the aerators are classed under the residual machinery entry (machines not specified elsewhere) and subject to GST under the residual entry.
Paddle wheel aerators used in aquaculture do not fall within the specific agricultural machinery heading (HSN 8436) because that entry is limited to machineries used in agriculture, horticulture, forestry, poultry and bee keeping; ejusdem generis and noscitur a sociis principles and the popular meaning of "agriculture" were applied, and notification definitions are confined to their own notifications. A press release is not binding for tariff classification. Absent a specific tariff entry, the aerators are classed under the residual machinery entry (machines not specified elsewhere) and subject to GST under the residual entry.
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