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...
Customs classification of facsimile machines turns on the tariff language, with HSN Explanatory Notes serving only as an interpretative aid where the language is ambiguous and not as a restriction on statutory wording. The note explains that "capable of connecting" to a network does not require built-in direct cable connectivity; operation through an ATA or similar external interface may satisfy the requirement. Where Revenue seeks to replace an accepted import classification, it must provide cogent technical evidence rather than rely on presumption or HSN interpretation alone. It further states that disclosed goods examined at assessment cannot attract extended limitation absent proven concealment, withheld specifications, or false declaration.
Customs classification of facsimile machines turns on the tariff language, with HSN Explanatory Notes serving only as an interpretative aid where the language is ambiguous and not as a restriction on statutory wording. The note explains that "capable of connecting" to a network does not require built-in direct cable connectivity; operation through an ATA or similar external interface may satisfy the requirement. Where Revenue seeks to replace an accepted import classification, it must provide cogent technical evidence rather than rely on presumption or HSN interpretation alone. It further states that disclosed goods examined at assessment cannot attract extended limitation absent proven concealment, withheld specifications, or false declaration.
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