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 telecom equipment was classified by applying the functional test to its actual working. The Airspan Air Velocity 2700 was found to receive signals from the tower, synchronize them and route them through lines within the enclosed area to support a 5G network efficiently. On that functional character, the classification declared by the importer under Customs Tariff Heading 8517 6260 was upheld, and the alternative classification as other transmission or routing apparatus was not accepted.
Imported telecom equipment was classified by applying the functional test to its actual working. The Airspan Air Velocity 2700 was found to receive signals from the tower, synchronize them and route them through lines within the enclosed area to support a 5G network efficiently. On that functional character, the classification declared by the importer under Customs Tariff Heading 8517 6260 was upheld, and the alternative classification as other transmission or routing apparatus was not accepted.
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