Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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The sole issue is tariff classification under Heading 9021: whether the Onyx embolization system is an "artificial part of the body" (CTI 9021 31/39) or an implanted appliance compensating for a defect (CTI 9021 90 90). Applying GRI 1 and Explanatory Notes, the authority finds classification turns on anatomical replacement: artificial parts must substitute or replicate body structure. The Onyx system occludes vascular defects to induce thrombosis and does not replace or restore anatomical structure; therefore it is not classifiable under 9021 31/39 and is held classifiable under CTI 9021 90 90. - AAR
The sole issue is tariff classification under Heading 9021: whether the Onyx embolization system is an "artificial part of the body" (CTI 9021 31/39) or an implanted appliance compensating for a defect (CTI 9021 90 90). Applying GRI 1 and Explanatory Notes, the authority finds classification turns on anatomical replacement: artificial parts must substitute or replicate body structure. The Onyx system occludes vascular defects to induce thrombosis and does not replace or restore anatomical structure; therefore it is not classifiable under 9021 31/39 and is held classifiable under CTI 9021 90 90. - AAR
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