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...
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Manufacture for central excise requires transformation into a new, distinct and marketable commodity with a separate name, character and use; labour, skill, expense or value addition alone does not suffice. Kitting imported photocopier modules by unpacking and placing them into customer-specific sets was not manufacture where the components remained in original packing, no physical assembly occurred at the warehouse, and relevant fittings had been made abroad. Note 6 to Section XVI could not deem manufacture because the modules were imported and assessed as complete machines, with no subsequent conversion of incomplete goods into complete articles. Rule 2(a) governs classification only and does not determine manufacture. The excise-duty demand was unsustainable.
Manufacture for central excise requires transformation into a new, distinct and marketable commodity with a separate name, character and use; labour, skill, expense or value addition alone does not suffice. Kitting imported photocopier modules by unpacking and placing them into customer-specific sets was not manufacture where the components remained in original packing, no physical assembly occurred at the warehouse, and relevant fittings had been made abroad. Note 6 to Section XVI could not deem manufacture because the modules were imported and assessed as complete machines, with no subsequent conversion of incomplete goods into complete articles. Rule 2(a) governs classification only and does not determine manufacture. The excise-duty demand was unsustainable.
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