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...
Parts of an inverter intended for use with an electric vehicle eAxle were held classifiable under Chapter 85 rather than Heading 8708, because electrical machinery is excluded from "parts and accessories" of motor vehicles by Note 2(f) to Section XVII, and classification must follow the sequential scheme of Note 2, applying Note 2(a) where a part is covered by a Chapter 84/85 heading without resort to Note 2(b)/(c). Accordingly, specified inverter components identifiable as inverter parts were classified under CTI 85049090. A request to keep the ruling confidential was rejected as no technical or commercially sensitive information was shown to warrant protection under Regulation 27. - AAR
Parts of an inverter intended for use with an electric vehicle eAxle were held classifiable under Chapter 85 rather than Heading 8708, because electrical machinery is excluded from "parts and accessories" of motor vehicles by Note 2(f) to Section XVII, and classification must follow the sequential scheme of Note 2, applying Note 2(a) where a part is covered by a Chapter 84/85 heading without resort to Note 2(b)/(c). Accordingly, specified inverter components identifiable as inverter parts were classified under CTI 85049090. A request to keep the ruling confidential was rejected as no technical or commercially sensitive information was shown to warrant protection under Regulation 27. - AAR
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