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...
Brand rate drawback on exported bus bodies was discussed in relation to simultaneous DEPB benefit for chassis components. The notes state that the 1988 circular's average-rate dispensation did not require independent body builders to furnish duty-paid documents, and that the 2003 circular continued this approach after DEPB was introduced. They further state that double reimbursement could not be presumed solely from DEPB availing without material showing reimbursement of the same duty incidence. Recovery proceedings for wrongly granted drawback were treated as distinct from brand-rate revision and subject to Rule 16, requiring initiation within a reasonable time rather than automatic application of customs-duty limitation. The impugned denial and recovery were quashed for covered exports.
Brand rate drawback on exported bus bodies was discussed in relation to simultaneous DEPB benefit for chassis components. The notes state that the 1988 circular's average-rate dispensation did not require independent body builders to furnish duty-paid documents, and that the 2003 circular continued this approach after DEPB was introduced. They further state that double reimbursement could not be presumed solely from DEPB availing without material showing reimbursement of the same duty incidence. Recovery proceedings for wrongly granted drawback were treated as distinct from brand-rate revision and subject to Rule 16, requiring initiation within a reasonable time rather than automatic application of customs-duty limitation. The impugned denial and recovery were quashed for covered exports.
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