Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The dominant issue was whether an imported implantable intracranial "stent" was classifiable as an "artificial part of the body" under CTI 9021 39 00 or under the residual implanted appliances entry CTI 9021 90 90. Applying the scope of Heading 9021 and the anatomical replacement test, the authority held that the device functions therapeutically as a scaffold to retain embolization coils and achieve occlusion, without replicating or substituting any anatomical vessel or aneurysm wall segment. Since it is not a prosthetic substitute and the competing entries must be compared at the same hierarchical level, classification under "artificial parts" was rejected and the product was classified under CTI 9021 90 90. - AAR
The dominant issue was whether an imported implantable intracranial "stent" was classifiable as an "artificial part of the body" under CTI 9021 39 00 or under the residual implanted appliances entry CTI 9021 90 90. Applying the scope of Heading 9021 and the anatomical replacement test, the authority held that the device functions therapeutically as a scaffold to retain embolization coils and achieve occlusion, without replicating or substituting any anatomical vessel or aneurysm wall segment. Since it is not a prosthetic substitute and the competing entries must be compared at the same hierarchical level, classification under "artificial parts" was rejected and the product was classified under CTI 9021 90 90. - AAR
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
