Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
Tariff classification of Digital Axle Counters affirmed as electro-mechanical railway signalling equipment, eliminating duty, confiscation and penalty...
Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
Transfer-pricing comparability requires functional similarity and reliable current-year segmental data. Bilcare Ltd. was excluded because of diversified operations, unavailable segmental data, and its pharmaceutical packaging profile, which differed from paper-based aseptic packaging for food and drink products. Karur KCP Packaging Ltd. was excluded because it produced kraft paper and polypropylene bags principally for the cement industry, making its products materially dissimilar. Earlier-year segmental data could not support current-year inclusion where relevant data was unavailable. The Tribunal's fact-based comparability findings disclosed neither error nor perversity, so no substantial question of law arose and the Revenue's appeal was dismissed; the separate Revenue appeal issue remained open.
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TaxTMI 
TaxTMI 
of 4886 
