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...
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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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AMOLED display assembly imported for cellular mobile phones was classified under tariff item 85249220 as an OLED flat panel display module, not under tariff item 85177990 as parts of heading 8517. The Authority applied the terms of the competing headings, Chapter 85 Note 7, HSN Explanatory Notes and Section XVI Note 2(a), holding that modules remain classifiable as display modules even where they include driver or control circuits needed for display operation. The exclusion for modules with video-converting components was found inapplicable because the applicant did not show that the goods contained sophisticated signal-processing components giving them the character of another heading. The specific OLED entry therefore prevailed over a residual parts classification.
AMOLED display assembly imported for cellular mobile phones was classified under tariff item 85249220 as an OLED flat panel display module, not under tariff item 85177990 as parts of heading 8517. The Authority applied the terms of the competing headings, Chapter 85 Note 7, HSN Explanatory Notes and Section XVI Note 2(a), holding that modules remain classifiable as display modules even where they include driver or control circuits needed for display operation. The exclusion for modules with video-converting components was found inapplicable because the applicant did not show that the goods contained sophisticated signal-processing components giving them the character of another heading. The specific OLED entry therefore prevailed over a residual parts classification.
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