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 Hard Disk Drives - The design of the Schedule encompassing all products within the tariff enumeration does not offer scope for traversing beyond the ninety eight chapters making it evident that certainty of fitment is one of the characteristics of classification for smooth operation of international trade - the settled classification may be unsettled only by argument of inapplicability owing to distinguishable nature of the product. Such argument has not been put forth in the contentions of Learned Authorized Representative. - AT
Classification of Hard Disk Drives - The design of the Schedule encompassing all products within the tariff enumeration does not offer scope for traversing beyond the ninety eight chapters making it evident that certainty of fitment is one of the characteristics of classification for smooth operation of international trade - the settled classification may be unsettled only by argument of inapplicability owing to distinguishable nature of the product. Such argument has not been put forth in the contentions of Learned Authorized Representative. - AT
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