Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Classification of imported roasted areca nuts as roasted or dried remained pending adjudication. Laboratory classification as dried areca nuts based solely on physical appearance was treated as insufficient for continued withholding because moisture content was within the prescribed limit and comparable consignments had been released on personal bond. The imported goods were directed to be provisionally released on personal bond, without a bank guarantee, while classification and consequential customs duty remain subject to pending proceedings. Consignments declared fit for consumption were to be physically delivered within a fortnight.
Classification of imported roasted areca nuts as roasted or dried remained pending adjudication. Laboratory classification as dried areca nuts based solely on physical appearance was treated as insufficient for continued withholding because moisture content was within the prescribed limit and comparable consignments had been released on personal bond. The imported goods were directed to be provisionally released on personal bond, without a bank guarantee, while classification and consequential customs duty remain subject to pending proceedings. Consignments declared fit for consumption were to be physically delivered within a fortnight.
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