Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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Washing, removal of waste and sizing of imported manganese ore were treated as processes that converted run-of-mine ore into manganese concentrates. The Tribunal, following its earlier ruling, held that where such processing changes ore into concentrate under the chapter note and HSN explanation, the concentrate becomes distinct from ore in law. An exemption confined to manganese ores could not be extended to concentrates, so the claimed CVD exemption was not available. The imported goods were therefore correctly classified as manganese concentrates, and denial of the notification benefit was upheld.
Washing, removal of waste and sizing of imported manganese ore were treated as processes that converted run-of-mine ore into manganese concentrates. The Tribunal, following its earlier ruling, held that where such processing changes ore into concentrate under the chapter note and HSN explanation, the concentrate becomes distinct from ore in law. An exemption confined to manganese ores could not be extended to concentrates, so the claimed CVD exemption was not available. The imported goods were therefore correctly classified as manganese concentrates, and denial of the notification benefit was upheld.
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