Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Classification of imported goods - items imported for deployment in their ‘motorcycle’ production lines - Usage as determinant, or subsuming within broader descriptions, must have specific sanction of the notes as laid down in rule 1 of the General Rules for the Interpretation of Import Tariff. It is also clear from the Rules that the comparison should be at ‘heading’ level before proceeding within the more appropriate of the two for identification of the applicable sub-heading and tariff item - the proposed heading is that of ‘parts and accessories’ of vehicles. - AT
Classification of imported goods - items imported for deployment in their ‘motorcycle’ production lines - Usage as determinant, or subsuming within broader descriptions, must have specific sanction of the notes as laid down in rule 1 of the General Rules for the Interpretation of Import Tariff. It is also clear from the Rules that the comparison should be at ‘heading’ level before proceeding within the more appropriate of the two for identification of the applicable sub-heading and tariff item - the proposed heading is that of ‘parts and accessories’ of vehicles. - AT
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