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 imported goods - Battery Fuse Units (BFU) - The tribunal examined whether the BFU should be classified under Chapter Heading 8529 as parts of Base Transmission Station (BTS) or Chapter Heading 8536 as 'Automatic Circuit Breakers.' After reviewing technical literature and customs tariff headings, they concluded that the BFU's functions align more with automatic circuit breakers, leading to classification under Chapter Heading 8536. Consequently, the tribunal ruled that the BFU does not qualify for exemption under Notification No.25/2005-Cus, as it does not meet the criteria as a part of the transmission apparatus specified in the notification.
Classification of imported goods - Battery Fuse Units (BFU) - The tribunal examined whether the BFU should be classified under Chapter Heading 8529 as parts of Base Transmission Station (BTS) or Chapter Heading 8536 as 'Automatic Circuit Breakers.' After reviewing technical literature and customs tariff headings, they concluded that the BFU's functions align more with automatic circuit breakers, leading to classification under Chapter Heading 8536. Consequently, the tribunal ruled that the BFU does not qualify for exemption under Notification No.25/2005-Cus, as it does not meet the criteria as a part of the transmission apparatus specified in the notification.
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