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 plastic decorative sheets, mouldings and wall panels are classified by applying the General Rules for Interpretation and the competing heading terms read with Chapter Note 10 to Chapter 39. The goods retained the essential character of plastic plates or sheets despite printing, embossing, UV coating and tongue-and-groove edges, which were treated as part of the original extrusion process rather than further working. Heading 3925 was confined to builders' ware not elsewhere specified or included, and the panels were found to be decorative overlays, not structural elements or ornamental architectural features. Classification therefore fell under heading 3921, with sub-classification depending on the polymer composition, subject to verification of the actual goods.
Imported plastic decorative sheets, mouldings and wall panels are classified by applying the General Rules for Interpretation and the competing heading terms read with Chapter Note 10 to Chapter 39. The goods retained the essential character of plastic plates or sheets despite printing, embossing, UV coating and tongue-and-groove edges, which were treated as part of the original extrusion process rather than further working. Heading 3925 was confined to builders' ware not elsewhere specified or included, and the panels were found to be decorative overlays, not structural elements or ornamental architectural features. Classification therefore fell under heading 3921, with sub-classification depending on the polymer composition, subject to verification of the actual goods.
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