Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
A customs exemption under Notification No. 24/2005-Cus, entry 13S, could not be denied merely because the importer did not follow the IGCR procedural requirements or furnish the prescribed undertaking, where the record showed the goods were only traded and not used in manufacture of excluded products. The Tribunal treated the exemption condition as aimed at preventing such manufacture and held that its substantive purpose was satisfied on the facts, so denial of exemption was unsustainable. It also rejected the objection that the adjudicating authority had travelled beyond the show cause notice, since the condition was reproduced there and the importer had put the exemption entry in issue. The duty demand, interest and penalty were set aside.
A customs exemption under Notification No. 24/2005-Cus, entry 13S, could not be denied merely because the importer did not follow the IGCR procedural requirements or furnish the prescribed undertaking, where the record showed the goods were only traded and not used in manufacture of excluded products. The Tribunal treated the exemption condition as aimed at preventing such manufacture and held that its substantive purpose was satisfied on the facts, so denial of exemption was unsustainable. It also rejected the objection that the adjudicating authority had travelled beyond the show cause notice, since the condition was reproduced there and the importer had put the exemption entry in issue. The duty demand, interest and penalty were set aside.
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