Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Clutch Master Cylinder and Concentric Slave Cylinder were examined for classification as linear-acting cylinders under CTH 8412 or as motor vehicle parts under CTH 8708. Applying the functional utility and predominant use test, and recognizing that end-use is a relevant aid in tariff classification, the goods were held to be specifically used as clutch components of motor vehicles, warranting classification as parts of clutches under CTI 87089300. The request to treat the ruling as confidential was rejected because no technical, proprietary, or commercially sensitive information was disclosed and the product details were already available in the public domain. - AAR
Clutch Master Cylinder and Concentric Slave Cylinder were examined for classification as linear-acting cylinders under CTH 8412 or as motor vehicle parts under CTH 8708. Applying the functional utility and predominant use test, and recognizing that end-use is a relevant aid in tariff classification, the goods were held to be specifically used as clutch components of motor vehicles, warranting classification as parts of clutches under CTI 87089300. The request to treat the ruling as confidential was rejected because no technical, proprietary, or commercially sensitive information was disclosed and the product details were already available in the public domain. - AAR
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