Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Imported aluminium formwork panels were treated as movable shuttering and support used for in situ pouring of concrete, not as moulds producing identifiable articles. On that basis, the text states that classification under CTH 84806000 was unsustainable, while CTH 76109010 for aluminium structures was accepted by reference to HSN explanatory notes. It also notes that demand enhancement based on a certificate of origin defect could not be sustained because that objection was not raised in the show cause notice, and the adjudicating authority had gone beyond its scope.
Imported aluminium formwork panels were treated as movable shuttering and support used for in situ pouring of concrete, not as moulds producing identifiable articles. On that basis, the text states that classification under CTH 84806000 was unsustainable, while CTH 76109010 for aluminium structures was accepted by reference to HSN explanatory notes. It also notes that demand enhancement based on a certificate of origin defect could not be sustained because that objection was not raised in the show cause notice, and the adjudicating authority had gone beyond its scope.
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