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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Aluminium formwork structures and accessories assembled at construction sites to support concrete while it sets, then removed, are described as aluminium structures rather than concrete moulds because they function as shuttering and support and do not produce separate concrete end-products. The text states that such goods fall under CTH 76109010, not CTH 84806000, following prior Tribunal reasoning for similar scaffolding, shuttering, propping or pit-propping equipment. On that classification, the claimed customs exemption for aluminium structures applies, and the demand was set aside with consequential relief.
Aluminium formwork structures and accessories assembled at construction sites to support concrete while it sets, then removed, are described as aluminium structures rather than concrete moulds because they function as shuttering and support and do not produce separate concrete end-products. The text states that such goods fall under CTH 76109010, not CTH 84806000, following prior Tribunal reasoning for similar scaffolding, shuttering, propping or pit-propping equipment. On that classification, the claimed customs exemption for aluminium structures applies, and the demand was set aside with consequential relief.
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