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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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EPCG duty-exemption compliance is evidenced by installation certificates for the installation requirement and an Export Obligation Discharge Certificate for fulfilment of export obligations. Where the licensing authority issues the discharge certificate after adjudication because it was pending despite an application and supporting documents, subsequent customs acceptance of that certificate and cancellation of the related bonds confirms compliance with EPCG notification conditions. A duty demand, redemption fine and penalty based solely on earlier non-production of the certificate are inconsistent with that subsequent acceptance of compliance.
EPCG duty-exemption compliance is evidenced by installation certificates for the installation requirement and an Export Obligation Discharge Certificate for fulfilment of export obligations. Where the licensing authority issues the discharge certificate after adjudication because it was pending despite an application and supporting documents, subsequent customs acceptance of that certificate and cancellation of the related bonds confirms compliance with EPCG notification conditions. A duty demand, redemption fine and penalty based solely on earlier non-production of the certificate are inconsistent with that subsequent acceptance of compliance.
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