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 primary issue is classification: the product is a processed betel-nut preparation (cleaning, cutting, dehydration, flavoring) meeting Chapter 21's supplementary note defining "betel nut product known as supari"; GIR 3(a) (most specific description) and CBIC guidance support placing it under CTH 2106 90 30 - outcome: classified under 21069030. The secondary issue is entitlement to exemption: Serial No. 39, Table 1, Notification No. 68/2012 covers all Chapter 21 goods (except certain alcoholic compounds); since the product falls under 21069030 it qualifies for the concession under Sr. No. 39. - AAR
The primary issue is classification: the product is a processed betel-nut preparation (cleaning, cutting, dehydration, flavoring) meeting Chapter 21's supplementary note defining "betel nut product known as supari"; GIR 3(a) (most specific description) and CBIC guidance support placing it under CTH 2106 90 30 - outcome: classified under 21069030. The secondary issue is entitlement to exemption: Serial No. 39, Table 1, Notification No. 68/2012 covers all Chapter 21 goods (except certain alcoholic compounds); since the product falls under 21069030 it qualifies for the concession under Sr. No. 39. - AAR
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