Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Petroleum-operation equipment moved from the DTA to an FTWZ after completion of its original contract and then returned to the DTA under a fresh essentiality certificate does not qualify for the residuary re-import exemption under Serial No. 5 of Notification No. 45/2017-Customs. The conditional petroleum-operation concession under Notification No. 50/2017-Customs is limited to certified use for the specified operation and includes its own transfer mechanism for eligible operations; an FTWZ movement cannot create an additional fiscal benefit. The SEZ statutory fiction is limited in scope, and equipment identity alone does not establish continuity with the original outward movement. FTWZ-to-DTA clearance for a new domestic contract is a fresh import, making the re-import exemption unavailable.
Petroleum-operation equipment moved from the DTA to an FTWZ after completion of its original contract and then returned to the DTA under a fresh essentiality certificate does not qualify for the residuary re-import exemption under Serial No. 5 of Notification No. 45/2017-Customs. The conditional petroleum-operation concession under Notification No. 50/2017-Customs is limited to certified use for the specified operation and includes its own transfer mechanism for eligible operations; an FTWZ movement cannot create an additional fiscal benefit. The SEZ statutory fiction is limited in scope, and equipment identity alone does not establish continuity with the original outward movement. FTWZ-to-DTA clearance for a new domestic contract is a fresh import, making the re-import exemption unavailable.
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