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...
For capital goods warehoused for manufacture or other operations, the requirement that goods be "intended for use" does not require actual installation or use in the warehouse. The notes distinguish intended use from actual use and state that, where imported goods were undisputedly intended for manufacturing operations, their later clearance for home consumption without use did not by itself attract interest on deferred customs duty. On that basis, the interest demand was treated as unsustainable, the challenged order was set aside, and consequential relief followed.
For capital goods warehoused for manufacture or other operations, the requirement that goods be "intended for use" does not require actual installation or use in the warehouse. The notes distinguish intended use from actual use and state that, where imported goods were undisputedly intended for manufacturing operations, their later clearance for home consumption without use did not by itself attract interest on deferred customs duty. On that basis, the interest demand was treated as unsustainable, the challenged order was set aside, and consequential relief followed.
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