Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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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