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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Duty drawback recovery under Rule 16, despite no express limitation period, must be initiated within a reasonable time based on the facts. The text states that delayed recovery may be sustainable where fraudulent availment or suppression is alleged, but non-production of proof of export-proceeds realisation alone does not establish either ground. Where recovery proceedings begin more than seven years after drawback payments and no explanation is given for the delay, the text treats the proceedings as time-barred. It also notes that the consequential demand and penalty were set aside.
Duty drawback recovery under Rule 16, despite no express limitation period, must be initiated within a reasonable time based on the facts. The text states that delayed recovery may be sustainable where fraudulent availment or suppression is alleged, but non-production of proof of export-proceeds realisation alone does not establish either ground. Where recovery proceedings begin more than seven years after drawback payments and no explanation is given for the delay, the text treats the proceedings as time-barred. It also notes that the consequential demand and penalty were set aside.
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