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...
Imported PVC, PS and PU wall panels, sheets and mouldings were held classifiable under Heading 3921 because, applying GRI 1 and Chapter Notes 10 and 11 to Chapter 39, their essential character remained that of plastic plates or sheets used as interior decorative coverings. The interlocking or profiled edges were treated as part of the extrusion process, not further working that would exclude them from Heading 3921. They were also not structural building elements or complex ornamental architectural features, so Heading 3925 for builders' ware did not apply. The products were classified in the relevant sub-headings based on their actual polymer composition, subject to verification.
Imported PVC, PS and PU wall panels, sheets and mouldings were held classifiable under Heading 3921 because, applying GRI 1 and Chapter Notes 10 and 11 to Chapter 39, their essential character remained that of plastic plates or sheets used as interior decorative coverings. The interlocking or profiled edges were treated as part of the extrusion process, not further working that would exclude them from Heading 3921. They were also not structural building elements or complex ornamental architectural features, so Heading 3925 for builders' ware did not apply. The products were classified in the relevant sub-headings based on their actual polymer composition, subject to verification.
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