Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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AAR held that the imported spectrum analyser models, equipped with telecom-standard applications (3GPP/LTE/5G NR), cellular band coverage and measurement of ACLR, EVM, phase noise and harmonic distortion, are "specially designed for telecommunications" and therefore classifiable under CTI 9030 40 00 of the First Schedule to the Customs Tariff Act, 1975. Rejecting the Department's plea for classification under the residuary "other" category, AAR applied the principle that a specific tariff entry prevails over a general one and found no evidence that the instruments were merely general-purpose. Classification under CTI 9030 40 00 is subject to verification of design and features at import.
AAR held that the imported spectrum analyser models, equipped with telecom-standard applications (3GPP/LTE/5G NR), cellular band coverage and measurement of ACLR, EVM, phase noise and harmonic distortion, are "specially designed for telecommunications" and therefore classifiable under CTI 9030 40 00 of the First Schedule to the Customs Tariff Act, 1975. Rejecting the Department's plea for classification under the residuary "other" category, AAR applied the principle that a specific tariff entry prevails over a general one and found no evidence that the instruments were merely general-purpose. Classification under CTI 9030 40 00 is subject to verification of design and features at import.
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