Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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An amount paid at import remains a refundable deposit where the bill of entry is unfinalised, no out-of-charge order for home consumption is issued, and the amount is not appropriated as customs duty. The imported pillow and duvet goods failed statutory quarantine requirements and were destroyed before clearance. As redemption fine and penalty were separately imposed and paid for the goods-related illegality, the pre-clearance deposit could not be retained as duty. The refund denial was set aside, and refund was granted with consequential relief in accordance with law.
An amount paid at import remains a refundable deposit where the bill of entry is unfinalised, no out-of-charge order for home consumption is issued, and the amount is not appropriated as customs duty. The imported pillow and duvet goods failed statutory quarantine requirements and were destroyed before clearance. As redemption fine and penalty were separately imposed and paid for the goods-related illegality, the pre-clearance deposit could not be retained as duty. The refund denial was set aside, and refund was granted with consequential relief in accordance with law.
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