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...
Seat covers designed to permanently fit over raw foam seats of vehicles by OEMs or seat manufacturers are classifiable under HSN 9401 as "Seats and parts thereof other than aircraft seats" or Sl. No. 435A under Schedule III of N/N. 1/2017-Central tax (rate) dt. 28.06.2017 as amended. Seat covers are accessories for protection and comfort, distinct from seats covered under 940120. To be classified under 8708, parts/accessories must be solely/principally for motor vehicles of 8701-8705, which seat covers satisfy. AAAR ruled seat covers merit classification under 8708 as usable only for motor vehicles.
Seat covers designed to permanently fit over raw foam seats of vehicles by OEMs or seat manufacturers are classifiable under HSN 9401 as "Seats and parts thereof other than aircraft seats" or Sl. No. 435A under Schedule III of N/N. 1/2017-Central tax (rate) dt. 28.06.2017 as amended. Seat covers are accessories for protection and comfort, distinct from seats covered under 940120. To be classified under 8708, parts/accessories must be solely/principally for motor vehicles of 8701-8705, which seat covers satisfy. AAAR ruled seat covers merit classification under 8708 as usable only for motor vehicles.
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