Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
An imported powdered Pelargonium sidoides root extract with maltodextrin carrier was classified as a standardized therapeutic preparation rather than a mere vegetable extract. Applying the HSN Notes and GRI 1 and 3(b), the Authority found that controlled extraction, concentration, drying and standardisation gave the goods the essential character of a medicament, intended for supply to pharmaceutical manufacturers for therapeutic or prophylactic use. It therefore ruled out Heading 1302 and Chapter 12, and classified the product under Heading 3003, specifically CTI 30039090, as a medicament not put up in measured doses or retail packing. Because the concessional customs notification applied only to Heading 1302 goods, the exemption was held unavailable.
An imported powdered Pelargonium sidoides root extract with maltodextrin carrier was classified as a standardized therapeutic preparation rather than a mere vegetable extract. Applying the HSN Notes and GRI 1 and 3(b), the Authority found that controlled extraction, concentration, drying and standardisation gave the goods the essential character of a medicament, intended for supply to pharmaceutical manufacturers for therapeutic or prophylactic use. It therefore ruled out Heading 1302 and Chapter 12, and classified the product under Heading 3003, specifically CTI 30039090, as a medicament not put up in measured doses or retail packing. Because the concessional customs notification applied only to Heading 1302 goods, the exemption was held unavailable.
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