Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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AAC bricks/blocks were held not to qualify as ceramic products under Chapter 69 because the manufacturing process and test material showed a sand-lime type article subjected to steam treatment in autoclaves, not goods fired after shaping or heated above the Chapter 69 threshold. The Authority applied HSN Notes and Chapter 69 Notes to conclude that heading 6810 better matched the product description. It also rejected the argument that tariff item 69041000 must prevail as a specific entry, since heading 6810 likewise contains a specific entry for building blocks and bricks. The goods were therefore classified under heading 6810, and classification under tariff item 69041000 was denied.
AAC bricks/blocks were held not to qualify as ceramic products under Chapter 69 because the manufacturing process and test material showed a sand-lime type article subjected to steam treatment in autoclaves, not goods fired after shaping or heated above the Chapter 69 threshold. The Authority applied HSN Notes and Chapter 69 Notes to conclude that heading 6810 better matched the product description. It also rejected the argument that tariff item 69041000 must prevail as a specific entry, since heading 6810 likewise contains a specific entry for building blocks and bricks. The goods were therefore classified under heading 6810, and classification under tariff item 69041000 was denied.
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