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 foam production line imported in CKD/SKD condition was treated as a complete and integrated injection moulding machine because all essential components were presented together and the process met the functional characteristics of injection moulding. The specific tariff item 8477 10 00 prevailed over residual entries, and the reaction injection moulding process did not take the goods outside that classification. For anti-dumping purposes, the notification was read as covering plastic processing or injection moulding machines in assembled, SKD or CKD form where they retain the essential character of the complete machine. The integrated 32-station system was assessed as one composite unit, and its cumulative clamping force brought it within the notified scope.
A foam production line imported in CKD/SKD condition was treated as a complete and integrated injection moulding machine because all essential components were presented together and the process met the functional characteristics of injection moulding. The specific tariff item 8477 10 00 prevailed over residual entries, and the reaction injection moulding process did not take the goods outside that classification. For anti-dumping purposes, the notification was read as covering plastic processing or injection moulding machines in assembled, SKD or CKD form where they retain the essential character of the complete machine. The integrated 32-station system was assessed as one composite unit, and its cumulative clamping force brought it within the notified scope.
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