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...
Mangala Borosan and Mangala G1 are not classifiable under Chapter Heading 3105 as Fertilisers as they lack essential fertilizing elements like Nitrogen, Phosphorus, or Potassium as stipulated by Chapter Notes. Classification is determined by product description, inclusion/exclusion in Section/Chapter Notes, and General Rules of Interpretation, not claimed usage or results. Appellant's contention of Nitrogen emanation during usage is untenable as products are assessed based on form and contents at presentation/supply. Definition of "Fertiliser" under relevant law requires essential plant nutrients like Nitrogen, Phosphorous, and Potassium, irrespective of State Government's notification of micronutrients. AAAR upheld classification outside Chapter 31.
Mangala Borosan and Mangala G1 are not classifiable under Chapter Heading 3105 as Fertilisers as they lack essential fertilizing elements like Nitrogen, Phosphorus, or Potassium as stipulated by Chapter Notes. Classification is determined by product description, inclusion/exclusion in Section/Chapter Notes, and General Rules of Interpretation, not claimed usage or results. Appellant's contention of Nitrogen emanation during usage is untenable as products are assessed based on form and contents at presentation/supply. Definition of "Fertiliser" under relevant law requires essential plant nutrients like Nitrogen, Phosphorous, and Potassium, irrespective of State Government's notification of micronutrients. AAAR upheld classification outside Chapter 31.
Note: It is a system-generated summary and is for quick reference only.