Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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Embedded Wi-Fi, cellular communication and navigation/positioning modules that cannot operate independently are treated as parts rather than complete communication apparatus. Where designed solely or principally for use with data-transmission or reception apparatus, Section Note 2(b) to Section XVI supports classification under Tariff Item 8517 79 90. The specific classification for communication-apparatus parts prevails over the general classification for electronic integrated circuits; modules that are neither aerials nor populated printed circuit boards fall within the residual parts entry. Modules not forming parts of cellular mobile phones or wrist-wearable devices, or inputs for making those excluded parts, qualify for nil basic customs duty subject to prescribed conditions, procedures and import verification.
Embedded Wi-Fi, cellular communication and navigation/positioning modules that cannot operate independently are treated as parts rather than complete communication apparatus. Where designed solely or principally for use with data-transmission or reception apparatus, Section Note 2(b) to Section XVI supports classification under Tariff Item 8517 79 90. The specific classification for communication-apparatus parts prevails over the general classification for electronic integrated circuits; modules that are neither aerials nor populated printed circuit boards fall within the residual parts entry. Modules not forming parts of cellular mobile phones or wrist-wearable devices, or inputs for making those excluded parts, qualify for nil basic customs duty subject to prescribed conditions, procedures and import verification.
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