Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Polypropylene packing boxes were treated as plastic packing articles under Chapter 39 because the material used was polypropylene and the manufacturing process produced moulded plastic goods. On that basis, the boxes were classified under heading 3923 and, as they did not fit any more specific sub-heading for boxes, cases or crates, were placed in tariff item 39231090. The associated plastic stoppers, lids, caps and covers were separately classified under the specific sub-heading for plastic closures in heading 3923 and, absent a more specific entry, under tariff item 39235090.
Polypropylene packing boxes were treated as plastic packing articles under Chapter 39 because the material used was polypropylene and the manufacturing process produced moulded plastic goods. On that basis, the boxes were classified under heading 3923 and, as they did not fit any more specific sub-heading for boxes, cases or crates, were placed in tariff item 39231090. The associated plastic stoppers, lids, caps and covers were separately classified under the specific sub-heading for plastic closures in heading 3923 and, absent a more specific entry, under tariff item 39235090.
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