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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
Redemption of confiscated prohibited foreign currency is discretionary, but the discretion must be exercised judiciously on the facts rather than rejected mechanically because the currency is prohibited. Where no material establishes a previous violation and the imposed penalty has been paid, refusal to permit redemption requires reconsideration. Redemption fine must remain within the statutory ceiling and follow principles governing release of confiscated foreign currency. The refusal of release was set aside, with redemption fine to be determined according to law and the currency released upon payment.
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