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...
Marine propulsion engine was classifiable under CTH 8408, specifically CTI 84081010, based on the tariff structure for compression-ignition internal combustion piston engines identifying marine propulsion engines as a distinct subheading; consequently, it attracted 5% IGST under Sl. No. 252 of Schedule I of N/N. 01/IGST (Rate) dated 28.06.2017. Marine engine spares, being parts suitable for use solely or principally with engines of heading 8408, were classifiable under CTH 8409, specifically CTI 84099990, and therefore also attracted 5% IGST under the same entry. Marine gear box was classifiable under CTH 8483, specifically CTI 84834000 as gear boxes and speed changers, and was likewise held eligible for 5% IGST under Sl. No. 252. - AAR
Marine propulsion engine was classifiable under CTH 8408, specifically CTI 84081010, based on the tariff structure for compression-ignition internal combustion piston engines identifying marine propulsion engines as a distinct subheading; consequently, it attracted 5% IGST under Sl. No. 252 of Schedule I of N/N. 01/IGST (Rate) dated 28.06.2017. Marine engine spares, being parts suitable for use solely or principally with engines of heading 8408, were classifiable under CTH 8409, specifically CTI 84099990, and therefore also attracted 5% IGST under the same entry. Marine gear box was classifiable under CTH 8483, specifically CTI 84834000 as gear boxes and speed changers, and was likewise held eligible for 5% IGST under Sl. No. 252. - AAR
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