Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
CESTAT held that imported refined oils and candelilla wax qualified for exemption under Notification No. 50/2017-Customs because approved laboratory reports showed the goods were of edible grade and there was no dispute on tariff classification. The notification required only that the goods fall under the specified headings and be refined edible grade; it did not impose any end-use requirement. The Tribunal also held that a CBEC circular could not add a condition not found in the notification, so the importer's declared use in cosmetics or pharmaceuticals could not defeat the exemption. The appellate order granting benefit under Serial Nos. 64 and 71 was upheld.
CESTAT held that imported refined oils and candelilla wax qualified for exemption under Notification No. 50/2017-Customs because approved laboratory reports showed the goods were of edible grade and there was no dispute on tariff classification. The notification required only that the goods fall under the specified headings and be refined edible grade; it did not impose any end-use requirement. The Tribunal also held that a CBEC circular could not add a condition not found in the notification, so the importer's declared use in cosmetics or pharmaceuticals could not defeat the exemption. The appellate order granting benefit under Serial Nos. 64 and 71 was upheld.
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