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...
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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