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...
The dominant issue was tariff classification of an imported smart vision sensor for resale, specifically whether it fell under Ch. 85 or under optical measuring/checking instruments. Applying GRI 1 and relevant explanatory notes, the authority found the product is specifically designed for automated industrial inspection and performs presence/orientation/defect checking by capturing images through integrated optical elements and executing AI-based comparison against pre-registered OK/NG data. As it does not perform general-purpose image recording or transmission and its principal function is optical image-based checking, it was held classifiable as "other optical instruments and appliances" under CTH 9031 49 00. - AAR
The dominant issue was tariff classification of an imported smart vision sensor for resale, specifically whether it fell under Ch. 85 or under optical measuring/checking instruments. Applying GRI 1 and relevant explanatory notes, the authority found the product is specifically designed for automated industrial inspection and performs presence/orientation/defect checking by capturing images through integrated optical elements and executing AI-based comparison against pre-registered OK/NG data. As it does not perform general-purpose image recording or transmission and its principal function is optical image-based checking, it was held classifiable as "other optical instruments and appliances" under CTH 9031 49 00. - AAR
Note: It is a system-generated summary and is for quick reference only.