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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When a product falls within both a general tariff entry and a specific entry, the specific entry prevails; Active Pharmaceutical Ingredients (APIs) and bulk drugs satisfy the statutory definition of "drug" and are classifiable under the specific entry SI. No. 226 for tariff rate purposes rather than under general chemical headings. The statutory definition of drug is wide and expressly includes substances intended as components of drugs, and regulatory treatment and definitions across drug control rules confirm that APIs retain their character as drugs even when imported for testing, bioequivalence, bioavailability or clinical trials. Consequently, APIs/bulk drugs attract IGST as per SI. No. 226 except where a nil-rated entry applies.
When a product falls within both a general tariff entry and a specific entry, the specific entry prevails; Active Pharmaceutical Ingredients (APIs) and bulk drugs satisfy the statutory definition of "drug" and are classifiable under the specific entry SI. No. 226 for tariff rate purposes rather than under general chemical headings. The statutory definition of drug is wide and expressly includes substances intended as components of drugs, and regulatory treatment and definitions across drug control rules confirm that APIs retain their character as drugs even when imported for testing, bioequivalence, bioavailability or clinical trials. Consequently, APIs/bulk drugs attract IGST as per SI. No. 226 except where a nil-rated entry applies.
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