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...
Classification of imported goods - poultry Feed Milling machinery - to be classified under CTH 9406 00 93 or under CTH 8436 10 00? - there is direct entry at CTH 8436 which speaks of machineries used in poultry keeping - there is no categorical assertion that the goods in question fall under “silos”. Further there is nothing to show by way of evidence that the imported goods have been used for “storing ensilage”. Therefore, the classification arrived at by the Adjudicating Authority cannot be agreed upon. - AT
Classification of imported goods - poultry Feed Milling machinery - to be classified under CTH 9406 00 93 or under CTH 8436 10 00? - there is direct entry at CTH 8436 which speaks of machineries used in poultry keeping - there is no categorical assertion that the goods in question fall under “silos”. Further there is nothing to show by way of evidence that the imported goods have been used for “storing ensilage”. Therefore, the classification arrived at by the Adjudicating Authority cannot be agreed upon. - AT
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