Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Section 35G excludes High Court jurisdiction where the question has a direct and proximate relation to the rate of duty, and excisability is part of that assessment; Section 35L therefore provides the proper forum, and the later insertion of Section 35L(2) was held clarificatory and retrospective. On merits, cutting, grooving, routing and fixing aluminium composite panels for site-specific installation did not amount to manufacture because the panels retained their essential identity, character and end use. Marketability is an independent requirement for excisability and must be proved by objective material, but it became irrelevant once no distinct goods emerged. The appeal was allowed and excise duty was held not attracted.
Section 35G excludes High Court jurisdiction where the question has a direct and proximate relation to the rate of duty, and excisability is part of that assessment; Section 35L therefore provides the proper forum, and the later insertion of Section 35L(2) was held clarificatory and retrospective. On merits, cutting, grooving, routing and fixing aluminium composite panels for site-specific installation did not amount to manufacture because the panels retained their essential identity, character and end use. Marketability is an independent requirement for excisability and must be proved by objective material, but it became irrelevant once no distinct goods emerged. The appeal was allowed and excise duty was held not attracted.
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