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...
Onus on Revenue to establish imported goods classifiable under Tariff Item 2710 1220 as Natural Gasoline Liquid (NGL) not discharged. Classification of goods as Naphtha under Tariff Item 27101290 declared by appellant held correct. When department fails to discharge burden of proving claimed classification, entire proceeding vitiated. Settled law that if department doesn't discharge onus for classification claim, appellant's declared classification upheld.
Onus on Revenue to establish imported goods classifiable under Tariff Item 2710 1220 as Natural Gasoline Liquid (NGL) not discharged. Classification of goods as Naphtha under Tariff Item 27101290 declared by appellant held correct. When department fails to discharge burden of proving claimed classification, entire proceeding vitiated. Settled law that if department doesn't discharge onus for classification claim, appellant's declared classification upheld.
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