Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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