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...
Classification of imported components for an electric vehicle eAxle turned on the application of Section XVII Notes and GIR 1. The reducer, being suitable for use solely/principally with motor vehicles of Chapter 87 and not integral/internal to the vehicle engine, was held classifiable as a transmission part under CTH 8708, akin to a gear box/differential based on its torque/speed reduction function. Ball bearings and tapered roller bearings were held excluded from Section XVII by Note 2(e) and classifiable irrespective of end-use under CTH 8482, with the relevant subheadings applied by bore diameter. The request to keep the ruling confidential was rejected for lack of specific justification. - AAR
Classification of imported components for an electric vehicle eAxle turned on the application of Section XVII Notes and GIR 1. The reducer, being suitable for use solely/principally with motor vehicles of Chapter 87 and not integral/internal to the vehicle engine, was held classifiable as a transmission part under CTH 8708, akin to a gear box/differential based on its torque/speed reduction function. Ball bearings and tapered roller bearings were held excluded from Section XVII by Note 2(e) and classifiable irrespective of end-use under CTH 8482, with the relevant subheadings applied by bore diameter. The request to keep the ruling confidential was rejected for lack of specific justification. - AAR
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