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...
Imported LCD panels were correctly classified under CTH 9013 because the goods had to be assessed as imported, and a specific heading naming liquid crystal devices prevails over generic motor-vehicle parts headings in CTH 8708/8714. Note 2(g) to Section XVII excludes Chapter 90 articles, and Note 3 could not override that exclusion merely because the panels were suitable for use in automotive instrument clusters. The Tribunal also rejected allegations of misdeclaration and suppression, finding no statutory requirement to declare end-use in the manner suggested, and that the Bills of Entry and supporting documents accurately described the goods. The demand was therefore barred by limitation and the extended period under Section 28(4) was unavailable.
Imported LCD panels were correctly classified under CTH 9013 because the goods had to be assessed as imported, and a specific heading naming liquid crystal devices prevails over generic motor-vehicle parts headings in CTH 8708/8714. Note 2(g) to Section XVII excludes Chapter 90 articles, and Note 3 could not override that exclusion merely because the panels were suitable for use in automotive instrument clusters. The Tribunal also rejected allegations of misdeclaration and suppression, finding no statutory requirement to declare end-use in the manner suggested, and that the Bills of Entry and supporting documents accurately described the goods. The demand was therefore barred by limitation and the extended period under Section 28(4) was unavailable.
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