Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Imported food seasoning material was held classifiable under CTI 3302 10 10 as a mixture based on odoriferous substances. The Tribunal found that Heading 3302 covers mixtures of odoriferous substances, or mixtures with a basis of one or more such substances, and that the presence of parsley, spearmint and paprika oleoresin satisfied that description. It rejected the view that an odoriferous substance must be the main or predominant constituent, holding that the HSN Explanatory Notes do not impose such a requirement. The reclassification under CTI 2103 90 40 was therefore unsustainable and the appeal was allowed.
Imported food seasoning material was held classifiable under CTI 3302 10 10 as a mixture based on odoriferous substances. The Tribunal found that Heading 3302 covers mixtures of odoriferous substances, or mixtures with a basis of one or more such substances, and that the presence of parsley, spearmint and paprika oleoresin satisfied that description. It rejected the view that an odoriferous substance must be the main or predominant constituent, holding that the HSN Explanatory Notes do not impose such a requirement. The reclassification under CTI 2103 90 40 was therefore unsustainable and the appeal was allowed.
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