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...
Applicability of Notification No. 20/98-CE to clearances by a 100% EOU turned on interpretation of the exemption conditions, not on fraud or suppression. Once the Larger Bench had settled the notification's applicability to the relevant DTA clearances, the only surviving issue was whether the remaining notification conditions were satisfied. Because the dispute was interpretational and no intent to evade duty was established, the ingredients for penalty under Section 11AC read with Rule 25 were absent. The penalties were therefore correctly set aside, and the remand was confined to verification of fulfilment of the notification conditions and consequential duty liability.
Applicability of Notification No. 20/98-CE to clearances by a 100% EOU turned on interpretation of the exemption conditions, not on fraud or suppression. Once the Larger Bench had settled the notification's applicability to the relevant DTA clearances, the only surviving issue was whether the remaining notification conditions were satisfied. Because the dispute was interpretational and no intent to evade duty was established, the ingredients for penalty under Section 11AC read with Rule 25 were absent. The penalties were therefore correctly set aside, and the remand was confined to verification of fulfilment of the notification conditions and consequential duty liability.
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