Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The Tribunal held that identical Electronic Power Steering ECU goods were governed by its earlier final order in the appellant's own case, and that binding coordinate-bench discipline required the same classification result because the earlier order had not been stayed despite challenge. It distinguished the later Chennai Bench view, noting that decision did not consider the appellant's prior case and turned on different facts. On that basis, EPS-ECU remained classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The impugned classification was upheld and the appeals were dismissed.
The Tribunal held that identical Electronic Power Steering ECU goods were governed by its earlier final order in the appellant's own case, and that binding coordinate-bench discipline required the same classification result because the earlier order had not been stayed despite challenge. It distinguished the later Chennai Bench view, noting that decision did not consider the appellant's prior case and turned on different facts. On that basis, EPS-ECU remained classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The impugned classification was upheld and the appeals were dismissed.
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