Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Imported consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
Imported consignments declared as industrial oil were held classifiable as Automotive Diesel Fuel/High-Speed Diesel under the 'most akin' test because combined laboratory reports unambiguously showed the samples comprised diesel fraction adulterated with lighter hydrocarbons and matched multiple HFHSD/ADF parameters; the product was therefore a restricted import. The court found cumulative CRCL and MRPL reports valid and sufficient since together they covered the prescribed Indian Standard parameters, sampling was undisputed, and substance of reports was not challenged. Testing in multiple accredited laboratories was permitted where one lab cannot cover all prescribed parameters and combined results satisfy the required tests.
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