Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
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