Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Calcined kaolin clay remained classifiable under Chapter 25 because Heading 2507 expressly covers kaolin and other kaolinic clays, whether or not calcined. The Tribunal found that the product information and chemical test report showed only calcined clay mainly composed of aluminium silicate with trace elements, which did not change its character for classification. It further held that the goods were not shown to be separate chemically defined compounds attracting Chapter 28. The reclassification under CTI 2839 9090 was rejected and CTI 2507 0029 was accepted.
Calcined kaolin clay remained classifiable under Chapter 25 because Heading 2507 expressly covers kaolin and other kaolinic clays, whether or not calcined. The Tribunal found that the product information and chemical test report showed only calcined clay mainly composed of aluminium silicate with trace elements, which did not change its character for classification. It further held that the goods were not shown to be separate chemically defined compounds attracting Chapter 28. The reclassification under CTI 2839 9090 was rejected and CTI 2507 0029 was accepted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
