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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Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
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