Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Non-injurious price in anti-dumping proceedings had to be disclosed with sufficient factual detail before final findings, because the calculation directly affected normal value, injury margin and the recommendation of nil duty. The Tribunal found that the disclosure statement did not explain the methodology or basis of the working, so the exporter could not effectively respond; disclosure after final findings caused prejudice and the nil-duty recommendation was set aside and remitted for fresh determination with reasonable opportunity. On product scope, semi-finished ophthalmic lenses with refractive index above 1.6 were upheld as excluded from the product under consideration because the domestic industry did not actually produce that category and the items were not technically or commercially substitutable.
Non-injurious price in anti-dumping proceedings had to be disclosed with sufficient factual detail before final findings, because the calculation directly affected normal value, injury margin and the recommendation of nil duty. The Tribunal found that the disclosure statement did not explain the methodology or basis of the working, so the exporter could not effectively respond; disclosure after final findings caused prejudice and the nil-duty recommendation was set aside and remitted for fresh determination with reasonable opportunity. On product scope, semi-finished ophthalmic lenses with refractive index above 1.6 were upheld as excluded from the product under consideration because the domestic industry did not actually produce that category and the items were not technically or commercially substitutable.
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