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...
Aluminium formwork structures used as shuttering and in-situ concrete support are discussed as classifiable under CTH 76109010 as aluminium structures rather than under CTH 84806000 as moulds. The analysis distinguishes reusable panels assembled at a construction site from moulds that produce separate concrete end-products. It notes that the Heading 7610 exclusion for moulds applies only where the article is in fact a mould. On this reasoning, custom-designed aluminium plates used for on-site construction support fall within the aluminium-structures classification, and reclassification as moulds is described as incorrect.
Aluminium formwork structures used as shuttering and in-situ concrete support are discussed as classifiable under CTH 76109010 as aluminium structures rather than under CTH 84806000 as moulds. The analysis distinguishes reusable panels assembled at a construction site from moulds that produce separate concrete end-products. It notes that the Heading 7610 exclusion for moulds applies only where the article is in fact a mould. On this reasoning, custom-designed aluminium plates used for on-site construction support fall within the aluminium-structures classification, and reclassification as moulds is described as incorrect.
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