Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
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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