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...
The article addresses tariff classification of antennas imported for base stations, holding that where the scope of competing tariff entries shows applicability as components, such antennas are classifiable as parts of a base station rather than as standalone machines for reception/conversion/transmission of data; the Tribunal's prior decision in Reliance Jio Infocomm reached this construction and was followed by a subsequent bench. The operative effect recorded is that orders classifying such antennas under the alternative tariff headings were set aside and the appeals allowing classification as parts were allowed.
The article addresses tariff classification of antennas imported for base stations, holding that where the scope of competing tariff entries shows applicability as components, such antennas are classifiable as parts of a base station rather than as standalone machines for reception/conversion/transmission of data; the Tribunal's prior decision in Reliance Jio Infocomm reached this construction and was followed by a subsequent bench. The operative effect recorded is that orders classifying such antennas under the alternative tariff headings were set aside and the appeals allowing classification as parts were allowed.
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