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...
The Authority treated the Fan Drive Assembly as a fluid coupling because it transmits torque through viscous fluid and matches Heading 8483.60.20, so the specific Chapter 84 heading prevailed over the general motor vehicle parts entry in Heading 8708. It also applied the tariff notes excluding Heading 8483 goods from Chapter 87 where they are integral engine parts. On GST, the product was covered by the notified entry for clutches and shaft couplings under Heading 8483 and attracted 18% tax. Separately procured parts and components, for which no specific sub-entry exists, were placed in the residual heading 8483.60.90.
The Authority treated the Fan Drive Assembly as a fluid coupling because it transmits torque through viscous fluid and matches Heading 8483.60.20, so the specific Chapter 84 heading prevailed over the general motor vehicle parts entry in Heading 8708. It also applied the tariff notes excluding Heading 8483 goods from Chapter 87 where they are integral engine parts. On GST, the product was covered by the notified entry for clutches and shaft couplings under Heading 8483 and attracted 18% tax. Separately procured parts and components, for which no specific sub-entry exists, were placed in the residual heading 8483.60.90.
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