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 of imported WD989/RLB989 tyres was determined by applying the General Rules for Interpretation, giving primacy to tariff headings and chapter/section notes and relying on manufacturer technical literature as reliable evidence of design and commercial identity. The Authority rejected end use alone as determinative and held that the tyres' design and technical parameters correspond to Truck and Bus Radial (TBR) type tyres. Operatively, the tyres are classifiable under HS subheading 4011 20 10 of the First Schedule to the Customs Tariff Act, 1975; asserted dominant mining use did not displace the design based classification.
Classification of imported WD989/RLB989 tyres was determined by applying the General Rules for Interpretation, giving primacy to tariff headings and chapter/section notes and relying on manufacturer technical literature as reliable evidence of design and commercial identity. The Authority rejected end use alone as determinative and held that the tyres' design and technical parameters correspond to Truck and Bus Radial (TBR) type tyres. Operatively, the tyres are classifiable under HS subheading 4011 20 10 of the First Schedule to the Customs Tariff Act, 1975; asserted dominant mining use did not displace the design based classification.
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