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...
By-products emerging from crude oil refining were treated as "resultant goods" under the MOOWR framework because the expression is to be understood in its ordinary and commercial sense, covering all goods produced in the manufacturing process and not only the principal output. The advance ruling also accepted that export of such resultant goods permits proportionate remission of duty on the imported crude oils attributable to the exported output, with correlation to be shown through proper accounting, yield ratios and material balance. Goods cleared for home consumption remain liable only to the corresponding attributable duty. The application was held maintainable as it concerned duty liability and remission under the warehousing scheme.
By-products emerging from crude oil refining were treated as "resultant goods" under the MOOWR framework because the expression is to be understood in its ordinary and commercial sense, covering all goods produced in the manufacturing process and not only the principal output. The advance ruling also accepted that export of such resultant goods permits proportionate remission of duty on the imported crude oils attributable to the exported output, with correlation to be shown through proper accounting, yield ratios and material balance. Goods cleared for home consumption remain liable only to the corresponding attributable duty. The application was held maintainable as it concerned duty liability and remission under the warehousing scheme.
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