Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
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