Ready-to-assemble greenhouse classification favours the specific tariff entry, while limitation extensions cannot revive expired excise demands.
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....Greenhouses cleared from the factory in ready-to-assemble condition fall under the specific tariff entry for greenhouses in ready-to-assemble sets rather than the general entry for plant growth chambers, applying Rule 3(a)'s preference for the most specific description. An amendment extending the normal excise-demand limitation period from one year to two years operates prospectively absent express retrospective effect and cannot revive a demand already time-barred. On that limitation basis, the duty demand, interest and penalty were set aside.....
TaxTMI