Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Imported aluminium tubes, pipes and profiles were held to be raw aluminium inputs classifiable under specific tariff headings rather than as motor vehicle parts; specific tariff entries prevail over generic Heading 8708, so the goods are not solely or principally for motor vehicle use and qualify for the exemption notifications, the effect being grant of exemption. Country-of-origin documentation satisfied origin requirements, so exemption applies. Misclassification was treated as interpretation, not misrepresentation, precluding invocation of extended limitation; consequentially interest and penalties and confiscation proposals were rejected.
Imported aluminium tubes, pipes and profiles were held to be raw aluminium inputs classifiable under specific tariff headings rather than as motor vehicle parts; specific tariff entries prevail over generic Heading 8708, so the goods are not solely or principally for motor vehicle use and qualify for the exemption notifications, the effect being grant of exemption. Country-of-origin documentation satisfied origin requirements, so exemption applies. Misclassification was treated as interpretation, not misrepresentation, precluding invocation of extended limitation; consequentially interest and penalties and confiscation proposals were rejected.
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