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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
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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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