Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Anti-dumping duty incurred on imports made while the notification was in force remained recoverable after expiry, because liability arose at import and customs recovery provisions applied to non-levy during that period. Under the EXIM Policy, manufacture required a process producing a new product with distinctive name, character or use; mere relabelling or segregation was insufficient, so the 100% EOU exemption could not be used where imported goods were diverted into the Domestic Tariff Area without manufacture. Penalty for wilful suppression was mandatory, subject to the statutory reduced-penalty option if paid within time. Anti-dumping duty was excluded from assessable value for CVD and SAD, and excise duty on DTA clearances could not be set off against customs or anti-dumping duty.
Anti-dumping duty incurred on imports made while the notification was in force remained recoverable after expiry, because liability arose at import and customs recovery provisions applied to non-levy during that period. Under the EXIM Policy, manufacture required a process producing a new product with distinctive name, character or use; mere relabelling or segregation was insufficient, so the 100% EOU exemption could not be used where imported goods were diverted into the Domestic Tariff Area without manufacture. Penalty for wilful suppression was mandatory, subject to the statutory reduced-penalty option if paid within time. Anti-dumping duty was excluded from assessable value for CVD and SAD, and excise duty on DTA clearances could not be set off against customs or anti-dumping duty.
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