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Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Classification dispute over imported Mukhwas (mouth freshener) centred on application of general rules of interpretation and the essential character test for mixtures. The authority analysed ingredient proportions (sugar-coated fennel ~50%, betel nut ~24%, seeds ~20%, plus sugar and dry coconut) and concluded betel nut is not the predominant or essential constituent. Trade/ commercial description was considered but composition determined classification. As a multi-ingredient food preparation not covered by specific pan masala or betel nut tariff entries, it is classifiable under the residual tariff for other food preparations (miscellaneous), with the ruling kept confidential.
Classification dispute over imported Mukhwas (mouth freshener) centred on application of general rules of interpretation and the essential character test for mixtures. The authority analysed ingredient proportions (sugar-coated fennel ~50%, betel nut ~24%, seeds ~20%, plus sugar and dry coconut) and concluded betel nut is not the predominant or essential constituent. Trade/ commercial description was considered but composition determined classification. As a multi-ingredient food preparation not covered by specific pan masala or betel nut tariff entries, it is classifiable under the residual tariff for other food preparations (miscellaneous), with the ruling kept confidential.
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