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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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The case involved the classification of imported spare parts for injection molding machines under Customs Tariff Heading 84779000 or 84771000. Allegations of anti-dumping duty were based on a notification regarding Horizonal Injection Molding Machines. The tribunal found that the imported goods did not meet the criteria for unassembled machines under Note (IV) of Section XVI. Rule 2(a) did not apply as the parts required complex processes for assembly. The engineer's report lacked details on essential features. The description of material indicated missing hydraulic system parts. The tribunal set aside the duty demand, allowing the appeals of the importers and dismissing the revenue's penalty imposition appeal.
The case involved the classification of imported spare parts for injection molding machines under Customs Tariff Heading 84779000 or 84771000. Allegations of anti-dumping duty were based on a notification regarding Horizonal Injection Molding Machines. The tribunal found that the imported goods did not meet the criteria for unassembled machines under Note (IV) of Section XVI. Rule 2(a) did not apply as the parts required complex processes for assembly. The engineer's report lacked details on essential features. The description of material indicated missing hydraulic system parts. The tribunal set aside the duty demand, allowing the appeals of the importers and dismissing the revenue's penalty imposition appeal.
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