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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Integrated Dynamic Brake was classified under heading 8708 as a motor vehicle part or accessory, with classification under headings 9032, 8413 and 8479 rejected. The product was not an automatic regulating or controlling instrument because it did not independently measure and regulate braking to a preset value, but functioned as part of the vehicle braking mechanism. It was also not classed under 8413, since the pump was only one integrated component and did not give the product its essential character, and not under 8479, because it had no independent function outside vehicle integration. It was held not to be a brake or an essential part of brakes, but an ancillary braking enhancement, so the residual entry 87089900 applied.
Integrated Dynamic Brake was classified under heading 8708 as a motor vehicle part or accessory, with classification under headings 9032, 8413 and 8479 rejected. The product was not an automatic regulating or controlling instrument because it did not independently measure and regulate braking to a preset value, but functioned as part of the vehicle braking mechanism. It was also not classed under 8413, since the pump was only one integrated component and did not give the product its essential character, and not under 8479, because it had no independent function outside vehicle integration. It was held not to be a brake or an essential part of brakes, but an ancillary braking enhancement, so the residual entry 87089900 applied.
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