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 focused on primary use: university answer booklets and bank passbooks are stationery intended for further writing and therefore classifiable under Chapter sub heading 4820, the security features being ancillary. Other printed items cut to size or requiring insertion of particulars are excluded from heading 4820 and fall under Chapter sub headings 4901/4911, following CBEC Circular No.1052/1/2017 as a binding classification clarification. Paper scrap arising as end cuttings during printing/finishing is not dutiable. The case is remanded for recomputation of demand and fresh adjudication on limitation and penal consequences after hearing.
Classification focused on primary use: university answer booklets and bank passbooks are stationery intended for further writing and therefore classifiable under Chapter sub heading 4820, the security features being ancillary. Other printed items cut to size or requiring insertion of particulars are excluded from heading 4820 and fall under Chapter sub headings 4901/4911, following CBEC Circular No.1052/1/2017 as a binding classification clarification. Paper scrap arising as end cuttings during printing/finishing is not dutiable. The case is remanded for recomputation of demand and fresh adjudication on limitation and penal consequences after hearing.
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