Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
An advance-ruling request on roasted areca nuts is barred where the identical classification issue has already been decided by a High Court and no new facts are presented; no ruling is issued on that question. Roasting is distinguished from drying because it produces material physical and chemical changes, and roasted nuts are treated as products otherwise prepared or preserved under Chapter 20. Applying the General Rules for Interpretation, tariff notes, HSN explanatory notes and common trade parlance, roasted cashews fall under the specific tariff entry for roasted cashew nuts, while roasted almonds and pistachios fall under the entry for other roasted nuts and seeds. Preferential customs-duty treatment requires proof of originating status under the applicable origin rules.
An advance-ruling request on roasted areca nuts is barred where the identical classification issue has already been decided by a High Court and no new facts are presented; no ruling is issued on that question. Roasting is distinguished from drying because it produces material physical and chemical changes, and roasted nuts are treated as products otherwise prepared or preserved under Chapter 20. Applying the General Rules for Interpretation, tariff notes, HSN explanatory notes and common trade parlance, roasted cashews fall under the specific tariff entry for roasted cashew nuts, while roasted almonds and pistachios fall under the entry for other roasted nuts and seeds. Preferential customs-duty treatment requires proof of originating status under the applicable origin rules.
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