Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Classification of the imported PVC four pipe extrusion line turned on the principal function test under Rule 1 read with Notes 3 and 4 to Section XVI. The Authority found that the system worked plastics by continuous extrusion through a die, with no clamping unit or mould cavity, so it was not an injection moulding machine. Because the extruder, die-head, calibration and cooling tanks, haul-off unit, cutter and control systems were functionally interdependent and directed to the single function of manufacturing PVC/CPVC pipes, the complete assembly was treated as a composite functional unit. It was accordingly classified under tariff item 8477 20 00 as extruders.
Classification of the imported PVC four pipe extrusion line turned on the principal function test under Rule 1 read with Notes 3 and 4 to Section XVI. The Authority found that the system worked plastics by continuous extrusion through a die, with no clamping unit or mould cavity, so it was not an injection moulding machine. Because the extruder, die-head, calibration and cooling tanks, haul-off unit, cutter and control systems were functionally interdependent and directed to the single function of manufacturing PVC/CPVC pipes, the complete assembly was treated as a composite functional unit. It was accordingly classified under tariff item 8477 20 00 as extruders.
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