Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Graphene cleared in a carrier medium (e.g., masterbatch or solvent) raises the issue whether it is classifiable as graphene under HSN 38019000 or by reference to the carrier. Applying Rule 3(b) of the General Rules for Interpretation, the product must be classified according to the component imparting its essential character; graphene, though functionally significant, merely enhances properties and does not displace the carrier's commercial and technical identity. Accordingly, no fixed heading was ruled in advance, and classification is to be determined at the time of clearance based on composition, predominant character, function, and market perception - AAR
Graphene cleared in a carrier medium (e.g., masterbatch or solvent) raises the issue whether it is classifiable as graphene under HSN 38019000 or by reference to the carrier. Applying Rule 3(b) of the General Rules for Interpretation, the product must be classified according to the component imparting its essential character; graphene, though functionally significant, merely enhances properties and does not displace the carrier's commercial and technical identity. Accordingly, no fixed heading was ruled in advance, and classification is to be determined at the time of clearance based on composition, predominant character, function, and market perception - AAR
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