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...
Customs detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.
Customs detention of imported goods is synonymous with seizure once the goods are under Customs control and cannot be cleared without permission; a formal seizure memo is only a later procedural step. The six-month period for issuing a show-cause notice therefore runs from initial detention. Any statutory extension of that period must be granted and communicated before the original period expires; a later extension is without jurisdiction. The time-barred extension was quashed and the goods were directed to be released upon an indemnity bond and proof that any sale would be solely for animal-feed use. Classification, duty liability and the goods' nature remain open for adjudication.
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