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...
Interpretation of an exemption notification for imported crude palm oil focused on acid value as the sole contested parameter. The tribunal applied a strict textual interpretation, holding that the phrase "acid value 4 or more" contains no upper limit, so no higher acid-value cutoff may be read into the notification; consequence: notification benefit cannot be denied on that ground. The tribunal further treated reprocessing and PHO clearance as operative compliance evidence, nullifying claims that the goods failed edible-grade standards and resulting in allowance of the appeals with consequential relief.
Interpretation of an exemption notification for imported crude palm oil focused on acid value as the sole contested parameter. The tribunal applied a strict textual interpretation, holding that the phrase "acid value 4 or more" contains no upper limit, so no higher acid-value cutoff may be read into the notification; consequence: notification benefit cannot be denied on that ground. The tribunal further treated reprocessing and PHO clearance as operative compliance evidence, nullifying claims that the goods failed edible-grade standards and resulting in allowance of the appeals with consequential relief.
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