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 e-rickshaw parts without motors and batteries did not acquire the essential character of complete electric tricycles for Rule 2(a) classification, because those components were necessary for self-propelled operation. The consignments were therefore only parts and not CKD vehicles, so the department's reclassification was unsustainable. On that basis, the challenge to dropping proceedings for the past Bills of Entry failed, while the live duty demand, confiscation, redemption fine and penalties were set aside; the investigation deposit was ordered to be released with applicable interest.
Imported e-rickshaw parts without motors and batteries did not acquire the essential character of complete electric tricycles for Rule 2(a) classification, because those components were necessary for self-propelled operation. The consignments were therefore only parts and not CKD vehicles, so the department's reclassification was unsustainable. On that basis, the challenge to dropping proceedings for the past Bills of Entry failed, while the live duty demand, confiscation, redemption fine and penalties were set aside; the investigation deposit was ordered to be released with applicable interest.
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