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...
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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