Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
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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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