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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
An advance ruling application is not maintainable where the same classification question is already pending in the applicant's own case before customs appellate fora or a court. The Authority held that disputes concerning Lithium Ion Cells and related components were already pending, and rejected the attempt to distinguish the cells by intended end use because classification turns on the goods' nature, composition and technical characteristics unless the tariff entry requires otherwise. It also held that the statutory bar applies to intrinsically connected goods and that partial admission is not contemplated; the application was therefore rejected in toto, with liberty to file a fresh application limited to goods not hit by the bar.
An advance ruling application is not maintainable where the same classification question is already pending in the applicant's own case before customs appellate fora or a court. The Authority held that disputes concerning Lithium Ion Cells and related components were already pending, and rejected the attempt to distinguish the cells by intended end use because classification turns on the goods' nature, composition and technical characteristics unless the tariff entry requires otherwise. It also held that the statutory bar applies to intrinsically connected goods and that partial admission is not contemplated; the application was therefore rejected in toto, with liberty to file a fresh application limited to goods not hit by the bar.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
