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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Imported draping tubes were treated as window curtain parts under Chapter 83 because the specific use-based description for articles of general use prevailed over the more generic tube-and-pipe description. The Tribunal also held that the declared classification could not be displaced merely on cross-sectional similarity, and the reclassification to Chapter 73 was unsustainable. BIS-based prohibition was inapplicable because the relevant tariff item was not covered by the quality control order, so confiscation under section 111(d) failed. The rejection of transaction value also failed because the valuation rules were not applied sequentially and a chartered engineer had no statutory role in that substitution. The impugned order was set aside.
Imported draping tubes were treated as window curtain parts under Chapter 83 because the specific use-based description for articles of general use prevailed over the more generic tube-and-pipe description. The Tribunal also held that the declared classification could not be displaced merely on cross-sectional similarity, and the reclassification to Chapter 73 was unsustainable. BIS-based prohibition was inapplicable because the relevant tariff item was not covered by the quality control order, so confiscation under section 111(d) failed. The rejection of transaction value also failed because the valuation rules were not applied sequentially and a chartered engineer had no statutory role in that substitution. The impugned order was set aside.
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