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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Geomembranes manufactured through a woven fabric stage followed by lamination were held classifiable under Chapter 59, specifically HSN 5911, rather than as plastic goods under Chapter 39. The Appellate Authority applied the binding jurisdictional precedent of the Gujarat High Court in an identical product dispute and treated that ruling as final. It rejected the Department's reliance on contrary case law, noting that the cited authority did not address woven fabric as a textile product and was therefore inapposite. On that basis, the advance ruling classifying geomembranes under HSN 5911 was upheld and the departmental appeal was dismissed.
Geomembranes manufactured through a woven fabric stage followed by lamination were held classifiable under Chapter 59, specifically HSN 5911, rather than as plastic goods under Chapter 39. The Appellate Authority applied the binding jurisdictional precedent of the Gujarat High Court in an identical product dispute and treated that ruling as final. It rejected the Department's reliance on contrary case law, noting that the cited authority did not address woven fabric as a textile product and was therefore inapposite. On that basis, the advance ruling classifying geomembranes under HSN 5911 was upheld and the departmental appeal was dismissed.
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