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...
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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