Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Whether imported racks are classifiable as electrical control apparatus and whether they attract concessional BCD. Applying Note 3 to Section XVI and GRI 3(a), the authority found the racks are composite/multi-functional with the principal function being distribution of electricity; the UPS within is ancillary (providing backup to networking equipment) and does not determine essential character. Explanatory Notes and the boards/panels description show Heading 8537 gives the more specific description than Headings 8504/8517/8543, so the racks are classifiable under 8537 10 90. Consequence: the racks are classed under 8537 10 90 and eligible for the concessional BCD under Notification No.45/2025 (S. No. 281). - AAR
Whether imported racks are classifiable as electrical control apparatus and whether they attract concessional BCD. Applying Note 3 to Section XVI and GRI 3(a), the authority found the racks are composite/multi-functional with the principal function being distribution of electricity; the UPS within is ancillary (providing backup to networking equipment) and does not determine essential character. Explanatory Notes and the boards/panels description show Heading 8537 gives the more specific description than Headings 8504/8517/8543, so the racks are classifiable under 8537 10 90. Consequence: the racks are classed under 8537 10 90 and eligible for the concessional BCD under Notification No.45/2025 (S. No. 281). - AAR
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