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...
Officers must not make direct references to DGFT for clarification on Foreign Trade Policy interpretation; such issues must first be examined at Group/Section level, escalated through the Deputy/Assistant Commissioner, and sent through the prescribed channel to the Board only after due scrutiny. Commodity-specific interpretational matters are to be referred only after examination and approval by the concerned NAC, where applicable. Any clarification proposal must include facts, relevant FTP provisions, the field view, specific points for clarification, affected case details, live consignments, and urgency. Consignments should not be held up solely for interpretational issues, and provisional assessment or other lawful facilitative measures should be considered to avoid delay in clearance.
Officers must not make direct references to DGFT for clarification on Foreign Trade Policy interpretation; such issues must first be examined at Group/Section level, escalated through the Deputy/Assistant Commissioner, and sent through the prescribed channel to the Board only after due scrutiny. Commodity-specific interpretational matters are to be referred only after examination and approval by the concerned NAC, where applicable. Any clarification proposal must include facts, relevant FTP provisions, the field view, specific points for clarification, affected case details, live consignments, and urgency. Consignments should not be held up solely for interpretational issues, and provisional assessment or other lawful facilitative measures should be considered to avoid delay in clearance.
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