Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Pine Bark Extract and Grape Seed Extract are classified as vegetable extracts under Heading 1302 rather than as food preparations under Heading 2106. Multi-stage extraction, concentration, drying, or adsorption does not exclude goods from Heading 1302 unless processing selectively enriches or depletes particular compounds or compound classes beyond ordinary solvent extraction. As single-ingredient botanical extracts imported in bulk as raw materials, the products were not finished food or dietary supplements for direct consumption. Because neither product was specifically enumerated within Heading 1302, both fall under the residual tariff item for other vegetable extracts, Customs Tariff Item 1302 19 39.
Pine Bark Extract and Grape Seed Extract are classified as vegetable extracts under Heading 1302 rather than as food preparations under Heading 2106. Multi-stage extraction, concentration, drying, or adsorption does not exclude goods from Heading 1302 unless processing selectively enriches or depletes particular compounds or compound classes beyond ordinary solvent extraction. As single-ingredient botanical extracts imported in bulk as raw materials, the products were not finished food or dietary supplements for direct consumption. Because neither product was specifically enumerated within Heading 1302, both fall under the residual tariff item for other vegetable extracts, Customs Tariff Item 1302 19 39.
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