Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Floating seals are discussed as classifiable by their sole or principal use as machinery parts under tariff heading 8431 rather than as mechanical seals under heading 8484 where no admissible evidence establishes use in other machinery or equipment. The notes state that supplier invoices disclosed the imported goods to Customs and that the dispute concerned classification; on that basis, invocation of the extended limitation period was not sustainable. The resulting demand, confiscation, redemption fine and penalty were consequently set aside, with the appeal allowed and consequential relief granted.
Floating seals are discussed as classifiable by their sole or principal use as machinery parts under tariff heading 8431 rather than as mechanical seals under heading 8484 where no admissible evidence establishes use in other machinery or equipment. The notes state that supplier invoices disclosed the imported goods to Customs and that the dispute concerned classification; on that basis, invocation of the extended limitation period was not sustainable. The resulting demand, confiscation, redemption fine and penalty were consequently set aside, with the appeal allowed and consequential relief granted.
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