Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Ultrasonic gas flow meters were classifiable either as flow-measuring instruments under Heading 9026 or as automatic regulating/controlling instruments under Heading 9032. The authority held that the goods, being standalone ultrasonic flow meters that only measure (and may transmit) flow data without any regulating or controlling function or interface to perform automatic control, are specifically covered by Heading 9026 under GIR 1 and the relevant Explanatory Notes; by virtue of Chapter 90 Note 2(a), they remain classifiable under Heading 9026 even if used as components in systems falling under Heading 9032. Consequently, in the absence of a specific eight-digit subheading for gas flow meters, classification was determined under CTI 9026 80 90. - AAR
Ultrasonic gas flow meters were classifiable either as flow-measuring instruments under Heading 9026 or as automatic regulating/controlling instruments under Heading 9032. The authority held that the goods, being standalone ultrasonic flow meters that only measure (and may transmit) flow data without any regulating or controlling function or interface to perform automatic control, are specifically covered by Heading 9026 under GIR 1 and the relevant Explanatory Notes; by virtue of Chapter 90 Note 2(a), they remain classifiable under Heading 9026 even if used as components in systems falling under Heading 9032. Consequently, in the absence of a specific eight-digit subheading for gas flow meters, classification was determined under CTI 9026 80 90. - AAR
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