Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Notification No. 45/2025-Customs is construed strictly: DSIR recognition is a necessary but not sufficient condition, because the importer must also show that each item is a notified consumable, essential for approved research, supported by the prescribed certificate, and actually used for the stated end use. On that basis, pre-Exhibit Batch R&D imports consumed or substantially used in experimentation, formulation, validation and related research can qualify, subject to full compliance with the conditions. Imports linked to the Exhibit Batch do not qualify if the goods are transferred to the manufacturing facility, or if the manufacturing facility itself imports them, because the eligible importer requirement and transfer prohibition are not met.
Notification No. 45/2025-Customs is construed strictly: DSIR recognition is a necessary but not sufficient condition, because the importer must also show that each item is a notified consumable, essential for approved research, supported by the prescribed certificate, and actually used for the stated end use. On that basis, pre-Exhibit Batch R&D imports consumed or substantially used in experimentation, formulation, validation and related research can qualify, subject to full compliance with the conditions. Imports linked to the Exhibit Batch do not qualify if the goods are transferred to the manufacturing facility, or if the manufacturing facility itself imports them, because the eligible importer requirement and transfer prohibition are not met.
Note: It is a system-generated summary and is for quick reference only.
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