Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Prior judicial determination of an identical classification issue bars an advance-ruling application where no material distinguishing facts or new circumstances are shown. Roasted areca nuts therefore could not be reconsidered on merits. Oven-roasted walnuts, whose roasting changes their flavour, colour and texture and makes them ready for consumption, are not treated as merely preserved nuts under Chapter 8. They fall under Customs Tariff Item 2008 19 91 as other roasted nuts and seeds. Concessional customs duty requires strict compliance with the applicable exemption notification, tariff entry and origin conditions prevailing on import; the importer must prove origin to the competent customs officer's satisfaction.
Prior judicial determination of an identical classification issue bars an advance-ruling application where no material distinguishing facts or new circumstances are shown. Roasted areca nuts therefore could not be reconsidered on merits. Oven-roasted walnuts, whose roasting changes their flavour, colour and texture and makes them ready for consumption, are not treated as merely preserved nuts under Chapter 8. They fall under Customs Tariff Item 2008 19 91 as other roasted nuts and seeds. Concessional customs duty requires strict compliance with the applicable exemption notification, tariff entry and origin conditions prevailing on import; the importer must prove origin to the competent customs officer's satisfaction.
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