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...
Thirteen imported items used in a lithium-ion cell production line were assessed for tariff classification and eligibility to concessional duty under a use-based exemption for "parts, sub-parts, inputs or raw materials" for manufacture of lithium-ion cells. Given their functional indispensability in cell manufacturing and the chapter-neutral wording and object of the exemption, they were held squarely covered, applying the principle that strict construction of exemptions must not defeat legislative purpose; benefit was allowed subject to strict IGCR, 2022 compliance and actual end-use in cells under tariff item 8507 60 00. The adhesive tapes were classified under 3919 10 00; polyether-modified polysiloxane under 3910 00 90; POLYSOL LB-150J under 3903 90 90; and PVDF under 3904 69 90 - AAR
Thirteen imported items used in a lithium-ion cell production line were assessed for tariff classification and eligibility to concessional duty under a use-based exemption for "parts, sub-parts, inputs or raw materials" for manufacture of lithium-ion cells. Given their functional indispensability in cell manufacturing and the chapter-neutral wording and object of the exemption, they were held squarely covered, applying the principle that strict construction of exemptions must not defeat legislative purpose; benefit was allowed subject to strict IGCR, 2022 compliance and actual end-use in cells under tariff item 8507 60 00. The adhesive tapes were classified under 3919 10 00; polyether-modified polysiloxane under 3910 00 90; POLYSOL LB-150J under 3903 90 90; and PVDF under 3904 69 90 - AAR
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