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...
Classification of goods - Sulphuric Acid, used in the manufacture of Agricultural Grade Zinc Sulphate - classified as fertiliser under Chapter 31 of CETA or classifiable under 28332990 of CETA - Both appellants successfully argued that despite Zinc Sulphate’s classification under a non-fertilizer tariff, its use as a fertilizer in agriculture justified the exemption. The Tribunal aligned with this broader, functional interpretation of the law, setting a precedent for similar cases, where the end use of the product determines its classification for tax purposes rather than strict adherence to tariff codes.
Classification of goods - Sulphuric Acid, used in the manufacture of Agricultural Grade Zinc Sulphate - classified as fertiliser under Chapter 31 of CETA or classifiable under 28332990 of CETA - Both appellants successfully argued that despite Zinc Sulphate’s classification under a non-fertilizer tariff, its use as a fertilizer in agriculture justified the exemption. The Tribunal aligned with this broader, functional interpretation of the law, setting a precedent for similar cases, where the end use of the product determines its classification for tax purposes rather than strict adherence to tariff codes.
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