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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Imported automatic soap dispensers were held classifiable under CTI 8424 89 90 as mechanical appliances for dispersing liquids. The Tribunal applied the distinction between dispersing and spraying, finding that the product senses the hand, mixes air with liquid soap, and dispenses foam through an outlet, but does not spray liquid. Because Chapter Heading 9616 covers sprays, including toiletry sprays, and its HSN notes exclude dispersing or spraying appliances covered by Chapter 8424, classification under CTI 9616 10 20 was rejected. The departmental classification was held erroneous and the contrary appellate order was set aside.
Imported automatic soap dispensers were held classifiable under CTI 8424 89 90 as mechanical appliances for dispersing liquids. The Tribunal applied the distinction between dispersing and spraying, finding that the product senses the hand, mixes air with liquid soap, and dispenses foam through an outlet, but does not spray liquid. Because Chapter Heading 9616 covers sprays, including toiletry sprays, and its HSN notes exclude dispersing or spraying appliances covered by Chapter 8424, classification under CTI 9616 10 20 was rejected. The departmental classification was held erroneous and the contrary appellate order was set aside.
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