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...
Whether the goods are classifiable as vegetable extracts (Chapter 13) or as medicaments (Chapter 30): applying HSN Explanatory Notes and Chapter Note 3 to Chapter 30, crude or single plant extracts remain within Heading 1302 unless compounded with other active ingredients or presented as medicaments; the goods are supplied in bulk powdered form, not in measured retail doses, and inert excipients merely facilitate powdering without altering therapeutic character. Held that the product is a simple vegetable extract classifiable under Heading 1302, subheading 130219 - Tariff Item 13021919. - AAR
Whether the goods are classifiable as vegetable extracts (Chapter 13) or as medicaments (Chapter 30): applying HSN Explanatory Notes and Chapter Note 3 to Chapter 30, crude or single plant extracts remain within Heading 1302 unless compounded with other active ingredients or presented as medicaments; the goods are supplied in bulk powdered form, not in measured retail doses, and inert excipients merely facilitate powdering without altering therapeutic character. Held that the product is a simple vegetable extract classifiable under Heading 1302, subheading 130219 - Tariff Item 13021919. - AAR
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