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...
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Fire-damaged motor cars brought with a vessel for ship-breaking may be classified as scrap where extensive damage has destroyed their identity and utility as motor vehicles, and salvage arrangements restrict disposal to demolition. Such goods are not restricted commercial or passenger vehicles, usable second-hand goods, or prohibited imports; confiscation for import without a licence is therefore not attracted. Unloading requires physical removal of cargo from a vessel; berthing at a notified ship-breaking port is not unloading. Where no unauthorised removal or other statutory contravention is established, neither the scrap cargo nor the vessel carrying it is liable to confiscation, and consequential penalties are unsustainable.
Note: It is a system-generated summary and is for quick reference only.