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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...
AAR ruled PVC raincoats must be classified under HSN 3926 20 (plastic articles) rather than HSN 6201 (textile garments), attracting 18% GST. While raincoats function as garments/apparel in common usage, the primary material composition of polyvinyl chloride (PVC) determines classification. PVC sheets cannot be considered woven fabric or textile materials. The ruling follows the principle of generalia specialibus non derogant, where specific provisions prevail over general ones. Despite being worn as apparel, the plastic composition makes it classifiable under "Articles of apparel and clothing accessories" in the plastics chapter, subject to Schedule-III tax rate regardless of price point.
AAR ruled PVC raincoats must be classified under HSN 3926 20 (plastic articles) rather than HSN 6201 (textile garments), attracting 18% GST. While raincoats function as garments/apparel in common usage, the primary material composition of polyvinyl chloride (PVC) determines classification. PVC sheets cannot be considered woven fabric or textile materials. The ruling follows the principle of generalia specialibus non derogant, where specific provisions prevail over general ones. Despite being worn as apparel, the plastic composition makes it classifiable under "Articles of apparel and clothing accessories" in the plastics chapter, subject to Schedule-III tax rate regardless of price point.
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