Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Transferable DFIA licences remained valid despite penalties imposed on the exporter, as they were not cancelled. The text explains that where proceedings against the exporter resulted in the duty demand being dropped and allegations against the importer were unproved, the importer could not be treated as having used fraudulent means to make duty-free imports. Those circumstances also did not justify invoking the extended limitation period. The customs-duty demand was therefore dropped, and the Revenue's appeal against that outcome was dismissed.
Transferable DFIA licences remained valid despite penalties imposed on the exporter, as they were not cancelled. The text explains that where proceedings against the exporter resulted in the duty demand being dropped and allegations against the importer were unproved, the importer could not be treated as having used fraudulent means to make duty-free imports. Those circumstances also did not justify invoking the extended limitation period. The customs-duty demand was therefore dropped, and the Revenue's appeal against that outcome was dismissed.
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