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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
Provisional preservation of areca nuts did not make the goods classifiable under heading 0812, because that heading applies only to goods that remain unsuitable for immediate consumption in that state. Relying on the reasoning in S. Krishna & Co., the Court held that the imported goods did not satisfy that condition and were therefore classifiable under tariff item 0802, not 0812. The substantial question on tariff classification was answered in favour of the department, and the appeal was allowed.
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