Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rough diamonds marked by Galaxy and DiaExpert laser systems were treated as processed rather than natural-state stones because scanning, mapping and surface marking were regarded as working/processing and as engraving under the tariff notes. Applying Rule 1 of the General Rules for Interpretation and the HSN notes to Heading 7102, the goods were classified under tariff item 71023990, not 71023100. On that basis, the customs exemption for rough diamonds under serial No. 345 of Notification No. 50/2017-Cus was denied because the goods were no longer rough diamonds in their natural state.
Rough diamonds marked by Galaxy and DiaExpert laser systems were treated as processed rather than natural-state stones because scanning, mapping and surface marking were regarded as working/processing and as engraving under the tariff notes. Applying Rule 1 of the General Rules for Interpretation and the HSN notes to Heading 7102, the goods were classified under tariff item 71023990, not 71023100. On that basis, the customs exemption for rough diamonds under serial No. 345 of Notification No. 50/2017-Cus was denied because the goods were no longer rough diamonds in their natural state.
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