Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The article determines that technical-grade Cyantraniliprole and Clothianidin are insecticidal preparations and thus classifiable under Heading 3808. Applying Chapter and HSN explanatory notes and GRI 3(a), the specific description for insecticidal preparations prevails over more general chemical headings; alternatively, GRI 3(b) supports classification by essential character derived from insecticidal function. Supplementary Note 2's mass-content threshold (>90%) is satisfied, bringing the goods within the specified tariff entry for technical-grade pesticides. Legislative amendments in the Finance Act, 2025 and product registration requirements under the Insecticides regime reinforce their regulatory identity as insecticides.
The article determines that technical-grade Cyantraniliprole and Clothianidin are insecticidal preparations and thus classifiable under Heading 3808. Applying Chapter and HSN explanatory notes and GRI 3(a), the specific description for insecticidal preparations prevails over more general chemical headings; alternatively, GRI 3(b) supports classification by essential character derived from insecticidal function. Supplementary Note 2's mass-content threshold (>90%) is satisfied, bringing the goods within the specified tariff entry for technical-grade pesticides. Legislative amendments in the Finance Act, 2025 and product registration requirements under the Insecticides regime reinforce their regulatory identity as insecticides.
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