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...
Imported parts/components/sub-assemblies intended for manufacture of interactive flat panel displays were examined for classification and consequent eligibility to concessional BCD under Notification No. 24/2005-Cus, Sr. No. 39 read with Sr. No. 8, subject to IGCR compliance. Applying the post-Budget 2025 tariff amendments and the binding CBIC Circular No. 12/2025-Cus issued under s.151A, interactive flat panel displays were held classifiable under CTI 8528 59 00 (monitors) and not under Heading 8471. Since Sr. No. 8 covers only goods falling under Heading 8471, the prerequisite for invoking Sr. No. 39 for inputs was not met; the claimed notification benefit was denied. - AAR
Imported parts/components/sub-assemblies intended for manufacture of interactive flat panel displays were examined for classification and consequent eligibility to concessional BCD under Notification No. 24/2005-Cus, Sr. No. 39 read with Sr. No. 8, subject to IGCR compliance. Applying the post-Budget 2025 tariff amendments and the binding CBIC Circular No. 12/2025-Cus issued under s.151A, interactive flat panel displays were held classifiable under CTI 8528 59 00 (monitors) and not under Heading 8471. Since Sr. No. 8 covers only goods falling under Heading 8471, the prerequisite for invoking Sr. No. 39 for inputs was not met; the claimed notification benefit was denied. - AAR
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