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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A proposed mixture of vegetable oils marketed as "Pooja Oil" and labelled "Not for Human Consumption" was classified under Chapter Heading 1518 because headings 15.07 to 15.15 cover single oils, heading 15.16 applies only to chemically transformed products, and heading 15.17 is limited to edible mixtures. The Authority treated the declared non-human use and marketing description as decisive, and rejected theoretical edibility as irrelevant. On that classification, the product fell within Entry No. 96 of Schedule I of Notification No. 9/2025-Central Tax (Rate) and was taxable at 5%, comprising 2.5% CGST and 2.5% SGST.
A proposed mixture of vegetable oils marketed as "Pooja Oil" and labelled "Not for Human Consumption" was classified under Chapter Heading 1518 because headings 15.07 to 15.15 cover single oils, heading 15.16 applies only to chemically transformed products, and heading 15.17 is limited to edible mixtures. The Authority treated the declared non-human use and marketing description as decisive, and rejected theoretical edibility as irrelevant. On that classification, the product fell within Entry No. 96 of Schedule I of Notification No. 9/2025-Central Tax (Rate) and was taxable at 5%, comprising 2.5% CGST and 2.5% SGST.
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