Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Tariff classification of oven-roasted nuts distinguishes roasting from drying: oven-heating that creates roasted characteristics is treated as roasting, placing almonds and pistachios within the residual entry for other roasted nuts and seeds. Cashew nuts fall within the specific tariff entry for roasted, salted, or roasted and salted cashews, rather than a general entry, under the specific-over-general classification principle. No fresh advance ruling is available on roasted areca nuts where materially indistinguishable classification issues have already been considered. Preferential customs-duty treatment requires independent verification at importation of originating status and prescribed documentary conditions; classification alone is insufficient.
Tariff classification of oven-roasted nuts distinguishes roasting from drying: oven-heating that creates roasted characteristics is treated as roasting, placing almonds and pistachios within the residual entry for other roasted nuts and seeds. Cashew nuts fall within the specific tariff entry for roasted, salted, or roasted and salted cashews, rather than a general entry, under the specific-over-general classification principle. No fresh advance ruling is available on roasted areca nuts where materially indistinguishable classification issues have already been considered. Preferential customs-duty treatment requires independent verification at importation of originating status and prescribed documentary conditions; classification alone is insufficient.
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