Deduction u/s 80P(2)(a)(i) and 80P(2)(d) on bank interest remanded for AO's verification, including classification of compulsory investments and relat...
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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