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...
Roasted areca nuts were held not classifiable as "roasted" because the claimed moisture content of 10-15% aligned with the benchmark treating such goods as "raw areca nut," with customs to verify by testing at import; consequently, the requested roasted-areca classification under the proposed tariff entry was denied. Oven-roasted cashew nuts were held specifically covered by the relevant tariff item and classified accordingly, while oven-roasted almond and pista nuts were held classifiable as "other roasted nuts and seeds" under the corresponding tariff item. Preferential BCD under the cited notifications was held available only upon satisfactory proof of origin under the applicable rules of origin and CAROTAR, 2020. - AAR
Roasted areca nuts were held not classifiable as "roasted" because the claimed moisture content of 10-15% aligned with the benchmark treating such goods as "raw areca nut," with customs to verify by testing at import; consequently, the requested roasted-areca classification under the proposed tariff entry was denied. Oven-roasted cashew nuts were held specifically covered by the relevant tariff item and classified accordingly, while oven-roasted almond and pista nuts were held classifiable as "other roasted nuts and seeds" under the corresponding tariff item. Preferential BCD under the cited notifications was held available only upon satisfactory proof of origin under the applicable rules of origin and CAROTAR, 2020. - AAR
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