Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Specific nil-rate exemption entries for namkeen and similar edible preparations apply to Cheese Balls and Bhujia cleared in sealed retail pouches. Cheese Balls fall within the specific entry for similar ready-to-consume edible preparations, while the residual packaged-food entry applies only where no specific description covers the goods; sealed packaging does not displace the specific exemption. Bhujia is expressly covered by a separate specific entry, and its sealed-container restriction cannot be imported from a differently worded residual entry. Classification under Tariff Item 2106 90 99 remains within sub-heading 2106 90, so it does not exclude eligibility where the exemption refers to that sub-heading. Nil-rate treatment consequently applies and related duty, interest and penalties are unsustainable.
Specific nil-rate exemption entries for namkeen and similar edible preparations apply to Cheese Balls and Bhujia cleared in sealed retail pouches. Cheese Balls fall within the specific entry for similar ready-to-consume edible preparations, while the residual packaged-food entry applies only where no specific description covers the goods; sealed packaging does not displace the specific exemption. Bhujia is expressly covered by a separate specific entry, and its sealed-container restriction cannot be imported from a differently worded residual entry. Classification under Tariff Item 2106 90 99 remains within sub-heading 2106 90, so it does not exclude eligibility where the exemption refers to that sub-heading. Nil-rate treatment consequently applies and related duty, interest and penalties are unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
