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 a composite "planter basket with needle-tufted coir liner" turned on application of GIR 3(b) as a composite good, since GIR 2(a) was inapplicable to a complete, assembled product; the essential character was held to be imparted by the iron basket, which is a finished ornamental/utilitarian article rather than a "part of general use" under Section XV notes, resulting in classification under CTH 8306.29.90. Classification of the coir liner when exported separately turned on Section XI Note 7 treating moulded/processed textile articles as "made-up"; the latex-sprayed, needle-felted coir liner, not covered elsewhere, fell under the residual heading for miscellaneous made-up textile articles, resulting in classification under CTH 6307.90.99. - AAR
Classification of a composite "planter basket with needle-tufted coir liner" turned on application of GIR 3(b) as a composite good, since GIR 2(a) was inapplicable to a complete, assembled product; the essential character was held to be imparted by the iron basket, which is a finished ornamental/utilitarian article rather than a "part of general use" under Section XV notes, resulting in classification under CTH 8306.29.90. Classification of the coir liner when exported separately turned on Section XI Note 7 treating moulded/processed textile articles as "made-up"; the latex-sprayed, needle-felted coir liner, not covered elsewhere, fell under the residual heading for miscellaneous made-up textile articles, resulting in classification under CTH 6307.90.99. - AAR
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