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...
Classification dispute over aluminium layered oil coolers turns on tariff scope and essential character: the units function solely as plate type heat exchangers transferring heat between oil and coolant and do not perform vehicle propulsion, transmission, steering, braking or structural functions. Applying GRI 1 and GRI 3(a), and Section XVII explanatory notes, the goods are specifically described by the subheading for plate type heat exchange units and are excluded from Chapter 87 motor vehicle parts. Consequently, the goods are classifiable under Customs Tariff Sub heading 8419.50.92 as plate type heat exchange units.
Classification dispute over aluminium layered oil coolers turns on tariff scope and essential character: the units function solely as plate type heat exchangers transferring heat between oil and coolant and do not perform vehicle propulsion, transmission, steering, braking or structural functions. Applying GRI 1 and GRI 3(a), and Section XVII explanatory notes, the goods are specifically described by the subheading for plate type heat exchange units and are excluded from Chapter 87 motor vehicle parts. Consequently, the goods are classifiable under Customs Tariff Sub heading 8419.50.92 as plate type heat exchange units.
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