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...
All four imported products were classified as relays under CTI 8536 49 00 because their principal function was to control, protect and supervise electrical systems, and the added digital or monitoring features were only ancillary under the principal function test and trade parlance. Exemption under Notification No. 12/2012 was available to the three products with a contact rating of 5 amperes, as no contrary evidence showed them to exceed the 7-ampere limit; MICOM was excluded because its contact rating above 7 amperes was not disputed. Penalties under sections 114A, 114AA, 112 and 114AA were set aside since the demand failed for the three products and the duty and interest relating to MICOM had been paid before the show cause notice.
All four imported products were classified as relays under CTI 8536 49 00 because their principal function was to control, protect and supervise electrical systems, and the added digital or monitoring features were only ancillary under the principal function test and trade parlance. Exemption under Notification No. 12/2012 was available to the three products with a contact rating of 5 amperes, as no contrary evidence showed them to exceed the 7-ampere limit; MICOM was excluded because its contact rating above 7 amperes was not disputed. Penalties under sections 114A, 114AA, 112 and 114AA were set aside since the demand failed for the three products and the duty and interest relating to MICOM had been paid before the show cause notice.
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