Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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AAR held that cathode-coated foils and anode-coated foils are classifiable as parts of electric accumulators under CTI 8507 90 90 by application of Section Note 2(b) to Section XVI, as they are solely/principally used in lithium-ion cells. The separator (microporous film) was classified under CTI 8507 90 10 as "parts of electric accumulators - accumulator cases made of hard rubber and separators." The LC breaker (cell protection device) was held to be an independent electrical protective apparatus classifiable under CTI 8536 30 00. All four items were held eligible for concessional BCD under Serial No. 314 of N/N. 45/2025-Cus., subject to IGCR, 2022 compliance and end-use verification, up to 31.03.2026.
AAR held that cathode-coated foils and anode-coated foils are classifiable as parts of electric accumulators under CTI 8507 90 90 by application of Section Note 2(b) to Section XVI, as they are solely/principally used in lithium-ion cells. The separator (microporous film) was classified under CTI 8507 90 10 as "parts of electric accumulators - accumulator cases made of hard rubber and separators." The LC breaker (cell protection device) was held to be an independent electrical protective apparatus classifiable under CTI 8536 30 00. All four items were held eligible for concessional BCD under Serial No. 314 of N/N. 45/2025-Cus., subject to IGCR, 2022 compliance and end-use verification, up to 31.03.2026.
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