Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Classification of a fortified soy protein product turned on the tariff terms, Chapter Notes and the General Rules for Interpretation rather than food-standard labels. Although Heading 3504 covers protein isolates, the product's 82% protein content, added calcium phosphate and fortified imported form showed it was not a plain soy protein isolate but a formulated nutritional preparation. The reliance on Codex and FSSAI standards was non-determinative for customs classification. Applying the HSN Notes to Heading 2106 and Chapter Note 5 to Chapter 21, the product was treated as a protein-based food preparation for enrichment of foods and beverages, and tariff item 21061000 was preferred over Heading 3504.
Classification of a fortified soy protein product turned on the tariff terms, Chapter Notes and the General Rules for Interpretation rather than food-standard labels. Although Heading 3504 covers protein isolates, the product's 82% protein content, added calcium phosphate and fortified imported form showed it was not a plain soy protein isolate but a formulated nutritional preparation. The reliance on Codex and FSSAI standards was non-determinative for customs classification. Applying the HSN Notes to Heading 2106 and Chapter Note 5 to Chapter 21, the product was treated as a protein-based food preparation for enrichment of foods and beverages, and tariff item 21061000 was preferred over Heading 3504.
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