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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Classification dispute over imported vitamin concentrates for animal feed focused on whether goods fall under animal feed preparations or chemically defined vitamins. The tribunal applied the common parlance/trade parlance test and held end use is a relevant factor but classification begins with GRI 1, applying headings and chapter notes primarily. Reliance on HSN is permissible only if fully aligned with the First Schedule, limiting HSN where divergences exist. Prior Tribunal authority classifying similar vitamin-containing imports as animal feed preparations under Heading 2309 was followed, resulting in the appeal being disposed in favour of classification as animal feed preparations.
Classification dispute over imported vitamin concentrates for animal feed focused on whether goods fall under animal feed preparations or chemically defined vitamins. The tribunal applied the common parlance/trade parlance test and held end use is a relevant factor but classification begins with GRI 1, applying headings and chapter notes primarily. Reliance on HSN is permissible only if fully aligned with the First Schedule, limiting HSN where divergences exist. Prior Tribunal authority classifying similar vitamin-containing imports as animal feed preparations under Heading 2309 was followed, resulting in the appeal being disposed in favour of classification as animal feed preparations.
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