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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Classification of the imported PVC four pipe extrusion line turned on the principal function test under Rule 1 read with Notes 3 and 4 to Section XVI. The Authority found that the system worked plastics by continuous extrusion through a die, with no clamping unit or mould cavity, so it was not an injection moulding machine. Because the extruder, die-head, calibration and cooling tanks, haul-off unit, cutter and control systems were functionally interdependent and directed to the single function of manufacturing PVC/CPVC pipes, the complete assembly was treated as a composite functional unit. It was accordingly classified under tariff item 8477 20 00 as extruders.
Classification of the imported PVC four pipe extrusion line turned on the principal function test under Rule 1 read with Notes 3 and 4 to Section XVI. The Authority found that the system worked plastics by continuous extrusion through a die, with no clamping unit or mould cavity, so it was not an injection moulding machine. Because the extruder, die-head, calibration and cooling tanks, haul-off unit, cutter and control systems were functionally interdependent and directed to the single function of manufacturing PVC/CPVC pipes, the complete assembly was treated as a composite functional unit. It was accordingly classified under tariff item 8477 20 00 as extruders.
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