Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Classification of automotive electronic control units depends on their distinct functions rather than the generic label "ECU". Body Control Modules and Integrated Body Units fall under the tariff entry for electronic automatic regulators, following an earlier Tribunal order in the same party's matter; absent any superior forum order altering that position, judicial discipline requires consistent treatment. Tyre Pressure Monitoring Systems were also accepted under that entry because the proposed motor-vehicle-parts classification lacked evidence establishing the functional characteristics required for reclassification. Revenue bears the burden of proving classification under a tariff heading different from that claimed, and the related demand and interest were set aside.
Classification of automotive electronic control units depends on their distinct functions rather than the generic label "ECU". Body Control Modules and Integrated Body Units fall under the tariff entry for electronic automatic regulators, following an earlier Tribunal order in the same party's matter; absent any superior forum order altering that position, judicial discipline requires consistent treatment. Tyre Pressure Monitoring Systems were also accepted under that entry because the proposed motor-vehicle-parts classification lacked evidence establishing the functional characteristics required for reclassification. Revenue bears the burden of proving classification under a tariff heading different from that claimed, and the related demand and interest were set aside.
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