Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
AAR held that heatsinks intended for exclusive use with PCBAs of data-center switches and uplink cards are classifiable as "parts" of telecommunication apparatus under CTH 8517, specifically CTI 8517 7990, and not as generic articles of base metal under headings 7326/7616. The authority found the heatsinks to be tailor-made, integral components with no independent utility, suitable for use solely or principally with equipment classified under heading 8517. Applying Section Note 2(b) of Section XVI, AAR concluded that such customized heatsinks form essential parts of the finished telecommunication apparatus and must follow the classification of the principal equipment.
AAR held that heatsinks intended for exclusive use with PCBAs of data-center switches and uplink cards are classifiable as "parts" of telecommunication apparatus under CTH 8517, specifically CTI 8517 7990, and not as generic articles of base metal under headings 7326/7616. The authority found the heatsinks to be tailor-made, integral components with no independent utility, suitable for use solely or principally with equipment classified under heading 8517. Applying Section Note 2(b) of Section XVI, AAR concluded that such customized heatsinks form essential parts of the finished telecommunication apparatus and must follow the classification of the principal equipment.
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