Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
The dominant issue was whether a stylus pen used with a digitizer screen is classifiable as an ADP machine unit under heading 8471. Applying Chapter Note 6(C), it was held that an X-Y coordinate input unit must be connectable to the CPU (through the digitizer) and capable of delivering data; the stylus pen satisfied these conditions as it interfaces via the screen and provides coordinate data. Technological advancement was treated as relevant to tariff interpretation, consistent with the principle against static construction of tariff terms, and a foreign ruling was considered only for persuasive value. The stylus pen was classified under sub-heading 84716090. - AAR
The dominant issue was whether a stylus pen used with a digitizer screen is classifiable as an ADP machine unit under heading 8471. Applying Chapter Note 6(C), it was held that an X-Y coordinate input unit must be connectable to the CPU (through the digitizer) and capable of delivering data; the stylus pen satisfied these conditions as it interfaces via the screen and provides coordinate data. Technological advancement was treated as relevant to tariff interpretation, consistent with the principle against static construction of tariff terms, and a foreign ruling was considered only for persuasive value. The stylus pen was classified under sub-heading 84716090. - AAR
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
