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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Video conferencing solutions and webcams were classified as apparatus for transmission or reception of voice, images or other data rather than parts of Automatic Data Processing (ADP) machines because they incorporate built in computing, support codecs and UVC, and some models run conferencing software in appliance mode without a host ADP. Applying the General Rules of Interpretation and Chapter notes excluding transmission/reception apparatus from ADP headings, the Authority concluded these goods do not fall within ADP machine parts and are classifiable under the residual tariff entry 8517 62 90.
Video conferencing solutions and webcams were classified as apparatus for transmission or reception of voice, images or other data rather than parts of Automatic Data Processing (ADP) machines because they incorporate built in computing, support codecs and UVC, and some models run conferencing software in appliance mode without a host ADP. Applying the General Rules of Interpretation and Chapter notes excluding transmission/reception apparatus from ADP headings, the Authority concluded these goods do not fall within ADP machine parts and are classifiable under the residual tariff entry 8517 62 90.
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