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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
AAR held that PVC sheeting does not constitute "fibres, filaments or yarns" and therefore articles manufactured from PVC sheetings are not textile goods within Chapter 62. PVC raincoats are excluded from headings 62012010, 62013010 and 62019010 and instead fall within Chapter 39 as articles of plastics, specifically heading 392620. The Authority found the Explanatory Notes to Chapter 39 dispositive and concluded the headings are mutually exclusive. Consequently, PVC raincoats are classifiable under HSN 392620 and taxable under Entry No. 111 of Schedule III (Notification No. 01/2017 - Central Tax), attracting an 18% GST rate on supply.
AAR held that PVC sheeting does not constitute "fibres, filaments or yarns" and therefore articles manufactured from PVC sheetings are not textile goods within Chapter 62. PVC raincoats are excluded from headings 62012010, 62013010 and 62019010 and instead fall within Chapter 39 as articles of plastics, specifically heading 392620. The Authority found the Explanatory Notes to Chapter 39 dispositive and concluded the headings are mutually exclusive. Consequently, PVC raincoats are classifiable under HSN 392620 and taxable under Entry No. 111 of Schedule III (Notification No. 01/2017 - Central Tax), attracting an 18% GST rate on supply.
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