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 goods - Folders for inserting certificates - The criteria being that all the printing or writing that is required to be done on the said cards is already done at the time of clearance and therefore, the same would be classifiable under Chapter 49. The same argument equally applies to folders for inserting certificates which contain already pre-printed details of the arguments and nothing remains to be written on the same. Relying on the aforesaid Circular and Chapter Note 12, it is apparent that the said product needs to be classifiable under Chapter 49 and not under Chapter 48.- AT
Classification of goods - Folders for inserting certificates - The criteria being that all the printing or writing that is required to be done on the said cards is already done at the time of clearance and therefore, the same would be classifiable under Chapter 49. The same argument equally applies to folders for inserting certificates which contain already pre-printed details of the arguments and nothing remains to be written on the same. Relying on the aforesaid Circular and Chapter Note 12, it is apparent that the said product needs to be classifiable under Chapter 49 and not under Chapter 48.- AT
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