Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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