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...
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
Social Welfare Surcharge on imports under MEIS/SEIS duty-credit scrips depends on customs duties levied and collected, rather than notional duty quantified or debited under an exemption mechanism. Where notifications exempt goods from basic customs duty and the equivalent amount is debited in scrips, the debit does not constitute actual duty realisation. The surcharge base is therefore nil, making a separate surcharge exemption unnecessary. The Board circular is characterised as clarificatory and applicable to pending earlier-period disputes, while warehousing and education-cess rulings are distinguishable.
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