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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
Imported molybdenum mirrors and shields, cut and curved for use in automobile lamps, ceased to retain the character of sheets and became distinct articles of molybdenum. Applying the General Rules for Interpretation and the principle that a product transformed into a new commercial and functional article cannot be classified as the original raw sheet, the Tribunal held that the goods were not classifiable under the tariff entry for bars, rods, profiles, plates, sheets, strips and foil. As the competing residual entry was the more appropriate classification, the goods were held classifiable under CTH 81029900 as other articles of molybdenum, and the departmental appeals were allowed.
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