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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
An advance ruling may be sought for ongoing import activity if it operates prospectively and does not disturb concluded imports, so the application was maintainable. Electric Vehicle Communication Controllers were classified under CTI 8517 62 90 because they function as apparatus for reception, conversion and transmission of data in a wired network, and the more specific Chapter 85 entry prevailed over Heading 8708. Preferential duty under Notifications 151/2009-Customs and 152/2009-Customs was denied because strict compliance with the Rules of Origin was required, and a mismatch between the tariff classification in the Proof of Origin and the Bill of Entry prevented verification of the origin criteria.
An advance ruling may be sought for ongoing import activity if it operates prospectively and does not disturb concluded imports, so the application was maintainable. Electric Vehicle Communication Controllers were classified under CTI 8517 62 90 because they function as apparatus for reception, conversion and transmission of data in a wired network, and the more specific Chapter 85 entry prevailed over Heading 8708. Preferential duty under Notifications 151/2009-Customs and 152/2009-Customs was denied because strict compliance with the Rules of Origin was required, and a mismatch between the tariff classification in the Proof of Origin and the Bill of Entry prevented verification of the origin criteria.
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