Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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AAR held the application maintainable and re-determined the tariff classification of imported "Nuclease Free Water." Applying Rule 1 of the General Rules for the Interpretation of the Import Tariff, it found the product to be pure, quality-tested water of a purity similar to distilled water, squarely covered under tariff item 28539010 of the Customs Tariff Act, 1975. The earlier treatment as certified reference material was held to be a misclassification based on erroneous interpretation. Relying on established jurisprudence that there is no estoppel in tax classification, AAR permitted reclassification and accepted the applicant's request for change in tariff heading.
AAR held the application maintainable and re-determined the tariff classification of imported "Nuclease Free Water." Applying Rule 1 of the General Rules for the Interpretation of the Import Tariff, it found the product to be pure, quality-tested water of a purity similar to distilled water, squarely covered under tariff item 28539010 of the Customs Tariff Act, 1975. The earlier treatment as certified reference material was held to be a misclassification based on erroneous interpretation. Relying on established jurisprudence that there is no estoppel in tax classification, AAR permitted reclassification and accepted the applicant's request for change in tariff heading.
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