Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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.
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