Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
AAR examined whether 69 plastic and metal components used in manufacturing cellular mobile phones qualified as "other mechanical items of plastic/metal" under Sr. 6D of N/N 57/2017, as amended. Applying contextual interpretation and ejusdem generis, AAR held that "mechanical items" must perform a function through mechanical action or provide structural support analogous to housings, gaskets, sockets, screws, antennas and similar components. It rejected a broad dictionary-based approach and declined to subsume films and protective materials already covered under other entries. AAR ruled that only Category A goods satisfying the mechanical/structural criteria are eligible for 10% BCD under Sr. 6D, while Category B goods are not entitled to the exemption.
AAR examined whether 69 plastic and metal components used in manufacturing cellular mobile phones qualified as "other mechanical items of plastic/metal" under Sr. 6D of N/N 57/2017, as amended. Applying contextual interpretation and ejusdem generis, AAR held that "mechanical items" must perform a function through mechanical action or provide structural support analogous to housings, gaskets, sockets, screws, antennas and similar components. It rejected a broad dictionary-based approach and declined to subsume films and protective materials already covered under other entries. AAR ruled that only Category A goods satisfying the mechanical/structural criteria are eligible for 10% BCD under Sr. 6D, while Category B goods are not entitled to the exemption.
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