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...
Insulated Gate Bipolar Transistors (IGBTs) were held classifiable as "transistors" under Customs Tariff Heading 8541, since they are three-terminal semiconductor devices (gate, collector, emitter) that control current flow for switching/amplification, matching the functional and structural definition in the Explanatory Notes. The Explanatory Notes also expressly identify IGBTs as an example of transistors, confirming their inclusion within heading 8541. Consequently, the goods were ruled classifiable under CTI 85412900 (transistors, other than photosensitive transistors-other), and not under any alternative classification. - AAR
Insulated Gate Bipolar Transistors (IGBTs) were held classifiable as "transistors" under Customs Tariff Heading 8541, since they are three-terminal semiconductor devices (gate, collector, emitter) that control current flow for switching/amplification, matching the functional and structural definition in the Explanatory Notes. The Explanatory Notes also expressly identify IGBTs as an example of transistors, confirming their inclusion within heading 8541. Consequently, the goods were ruled classifiable under CTI 85412900 (transistors, other than photosensitive transistors-other), and not under any alternative classification. - AAR
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