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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Roasted areca nut classification was not entertained because the issue was already covered by the Madras HC and, on the applicant's own moisture-content description of 10% to 15%, the goods were treated as raw areca nuts under heading 0802, not roasted nuts. For other nuts, the tariff and HSN notes were applied on the basis that roasting is a distinct process from drying or preservation; roasted cashew nuts fell under CTI 20081910, while roasted almond nuts and roasted pista nuts fell under CTI 20081991 as other roasted nuts. The preferential exemption under Notification No. 46/2011-Cus was held available only on proof of origin to the satisfaction of the proper officer under the applicable origin rules.
Roasted areca nut classification was not entertained because the issue was already covered by the Madras HC and, on the applicant's own moisture-content description of 10% to 15%, the goods were treated as raw areca nuts under heading 0802, not roasted nuts. For other nuts, the tariff and HSN notes were applied on the basis that roasting is a distinct process from drying or preservation; roasted cashew nuts fell under CTI 20081910, while roasted almond nuts and roasted pista nuts fell under CTI 20081991 as other roasted nuts. The preferential exemption under Notification No. 46/2011-Cus was held available only on proof of origin to the satisfaction of the proper officer under the applicable origin rules.
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