Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Gas compressors manufactured solely for use in motor-vehicle air-conditioning units were classified under Heading 8708 as parts and accessories of motor vehicles, not under Heading 8414, because goods meant only for vehicles in Chapter 87 are treated as vehicle parts and the more specific vehicle-heading prevailed. The classification under Heading 8708 was upheld. However, wilful suppression or fraud was not established where the taxpayer had consistently adopted the earlier accepted classification on a bona fide basis, so invocation of Section 74 and the associated penalty were set aside. The matter was remanded only for requantification of tax and fresh determination under Section 73.
Gas compressors manufactured solely for use in motor-vehicle air-conditioning units were classified under Heading 8708 as parts and accessories of motor vehicles, not under Heading 8414, because goods meant only for vehicles in Chapter 87 are treated as vehicle parts and the more specific vehicle-heading prevailed. The classification under Heading 8708 was upheld. However, wilful suppression or fraud was not established where the taxpayer had consistently adopted the earlier accepted classification on a bona fide basis, so invocation of Section 74 and the associated penalty were set aside. The matter was remanded only for requantification of tax and fresh determination under Section 73.
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