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 ...
Rough diamonds marked by Galaxy and DiaExpert laser systems were treated as processed rather than natural-state stones because scanning, mapping and surface marking were regarded as working/processing and as engraving under the tariff notes. Applying Rule 1 of the General Rules for Interpretation and the HSN notes to Heading 7102, the goods were classified under tariff item 71023990, not 71023100. On that basis, the customs exemption for rough diamonds under serial No. 345 of Notification No. 50/2017-Cus was denied because the goods were no longer rough diamonds in their natural state.
Rough diamonds marked by Galaxy and DiaExpert laser systems were treated as processed rather than natural-state stones because scanning, mapping and surface marking were regarded as working/processing and as engraving under the tariff notes. Applying Rule 1 of the General Rules for Interpretation and the HSN notes to Heading 7102, the goods were classified under tariff item 71023990, not 71023100. On that basis, the customs exemption for rough diamonds under serial No. 345 of Notification No. 50/2017-Cus was denied because the goods were no longer rough diamonds in their natural state.
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