Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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.