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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Applying GRI 1, the AAR held that kitchen exhaust hoods must be classified according to the tariff description and supporting product features. As the applicant did not establish that the goods incorporated a fan, they could not enter the fan-specific headings under 8414 59. The goods also fell outside tariff item 8414 60 00 because they exceeded 120 cm in horizontal side. Having been excluded from both specific entries, the hoods were classified under the residual tariff item 8414 80 90 as other hoods without a fan and exceeding the stated dimension.
Applying GRI 1, the AAR held that kitchen exhaust hoods must be classified according to the tariff description and supporting product features. As the applicant did not establish that the goods incorporated a fan, they could not enter the fan-specific headings under 8414 59. The goods also fell outside tariff item 8414 60 00 because they exceeded 120 cm in horizontal side. Having been excluded from both specific entries, the hoods were classified under the residual tariff item 8414 80 90 as other hoods without a fan and exceeding the stated dimension.
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