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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Vehicle Control Unit/Powertrain Control Unit for electric vehicles was examined for tariff classification among CTH 8537, 8543, 9032, and 8708/8714. Heading 8543 was rejected because the unit is not a standalone apparatus with an individual function and, under HSN Explanatory Notes, parts of machinery are excluded and classifiable as parts; hence it could not be treated as an independent electrical apparatus. Heading 9032 was also rejected because the unit neither measures parameters nor independently regulates/controls within the meaning of automatic regulating instruments under HSN criteria, but only processes sensor inputs and sends signals as part of the drivetrain; accordingly, it was held classifiable as vehicle parts under CTH 8708 (three-/four-wheelers) or CTH 8714 (two-wheelers). - AAR
Vehicle Control Unit/Powertrain Control Unit for electric vehicles was examined for tariff classification among CTH 8537, 8543, 9032, and 8708/8714. Heading 8543 was rejected because the unit is not a standalone apparatus with an individual function and, under HSN Explanatory Notes, parts of machinery are excluded and classifiable as parts; hence it could not be treated as an independent electrical apparatus. Heading 9032 was also rejected because the unit neither measures parameters nor independently regulates/controls within the meaning of automatic regulating instruments under HSN criteria, but only processes sensor inputs and sends signals as part of the drivetrain; accordingly, it was held classifiable as vehicle parts under CTH 8708 (three-/four-wheelers) or CTH 8714 (two-wheelers). - AAR
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