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...
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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