Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Imported dog and cat feed in 20 kg packs was examined for classification as "dog or cat food, put up for retail sale" under CTI 23091000 versus residual/bulk feed under CTI 23099010. Applying GIR 1 and 6, HSN Explanatory Notes, and the principle generalia specialibus non derogant, the goods were held to be consumer-ready pet food based on their completeness, packaging, and presentation, and not dependent on strict domestic labelling formalities such as MRP. Reliance on excise-related authorities and distinguishable precedents was rejected as inapplicable to customs classification. Consequently, classification under CTI 23091000 was affirmed, and CTI 23099010 was ruled out. - AAR
Imported dog and cat feed in 20 kg packs was examined for classification as "dog or cat food, put up for retail sale" under CTI 23091000 versus residual/bulk feed under CTI 23099010. Applying GIR 1 and 6, HSN Explanatory Notes, and the principle generalia specialibus non derogant, the goods were held to be consumer-ready pet food based on their completeness, packaging, and presentation, and not dependent on strict domestic labelling formalities such as MRP. Reliance on excise-related authorities and distinguishable precedents was rejected as inapplicable to customs classification. Consequently, classification under CTI 23091000 was affirmed, and CTI 23099010 was ruled out. - AAR
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