Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Whether imported cashew kernels described as provisionally preserved (nitrogen treated), roasted, and shelled/diced were classifiable under CTH 0801 or elsewhere was determined by applying GRI 1 and the specific-entry rule in GRI 3(a). Nitrogen treatment/packing was held not to be a recognised preservation method under the Tariff/HSN, and the goods retained the character of dried nuts; "diced" pieces of 2-7 mm were treated as broken kernels and classified under CTI 08013210. Roasted diced/broken cashew nuts were held to be "prepared/preserved" per HSN notes and classified under CTH 2008, specifically CTI 20081910. Shelled diced/broken cashew nuts, involving only shell removal and drying, were classified under CTI 08013210. - AAR
Whether imported cashew kernels described as provisionally preserved (nitrogen treated), roasted, and shelled/diced were classifiable under CTH 0801 or elsewhere was determined by applying GRI 1 and the specific-entry rule in GRI 3(a). Nitrogen treatment/packing was held not to be a recognised preservation method under the Tariff/HSN, and the goods retained the character of dried nuts; "diced" pieces of 2-7 mm were treated as broken kernels and classified under CTI 08013210. Roasted diced/broken cashew nuts were held to be "prepared/preserved" per HSN notes and classified under CTH 2008, specifically CTI 20081910. Shelled diced/broken cashew nuts, involving only shell removal and drying, were classified under CTI 08013210. - AAR
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
