Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
An advance ruling may be sought for ongoing import activity if it operates prospectively and does not disturb concluded imports, so the application was maintainable. Electric Vehicle Communication Controllers were classified under CTI 8517 62 90 because they function as apparatus for reception, conversion and transmission of data in a wired network, and the more specific Chapter 85 entry prevailed over Heading 8708. Preferential duty under Notifications 151/2009-Customs and 152/2009-Customs was denied because strict compliance with the Rules of Origin was required, and a mismatch between the tariff classification in the Proof of Origin and the Bill of Entry prevented verification of the origin criteria.
An advance ruling may be sought for ongoing import activity if it operates prospectively and does not disturb concluded imports, so the application was maintainable. Electric Vehicle Communication Controllers were classified under CTI 8517 62 90 because they function as apparatus for reception, conversion and transmission of data in a wired network, and the more specific Chapter 85 entry prevailed over Heading 8708. Preferential duty under Notifications 151/2009-Customs and 152/2009-Customs was denied because strict compliance with the Rules of Origin was required, and a mismatch between the tariff classification in the Proof of Origin and the Bill of Entry prevented verification of the origin criteria.
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