Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
Imported inverter assembly units used in mild hybrid vehicles were held to be "static converters" because they perform DC-AC inversion and AC-DC rectification through semiconductor switching devices with control circuitry, bringing them within HSN Explanatory Notes to heading 8504; they were therefore classified under tariff item 8504 40 90 rather than headings for vehicle parts or ignition/electrical equipment. Consequentially, since 8504 40 90 is covered by S. No. 646 of Notification No. 69/2011-Cus. and the goods were represented to be originating in Japan, the imports were held eligible for 0% basic customs duty subject to satisfaction of Japan CEPA origin conditions and CAROTAR, 2020 requirements. - AAR
Imported inverter assembly units used in mild hybrid vehicles were held to be "static converters" because they perform DC-AC inversion and AC-DC rectification through semiconductor switching devices with control circuitry, bringing them within HSN Explanatory Notes to heading 8504; they were therefore classified under tariff item 8504 40 90 rather than headings for vehicle parts or ignition/electrical equipment. Consequentially, since 8504 40 90 is covered by S. No. 646 of Notification No. 69/2011-Cus. and the goods were represented to be originating in Japan, the imports were held eligible for 0% basic customs duty subject to satisfaction of Japan CEPA origin conditions and CAROTAR, 2020 requirements. - AAR
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