Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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