Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
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