Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Post-clearance amendment of Bills of Entry may support preferential tariff claims under the India-Japan CEPA where a Certificate of Origin is issued retrospectively. Appendix-A to Annexure-2 of the CEPA Rules permits an importer lacking the certificate at importation to seek refund of excess duty after producing the certificate and supporting documents. Section 149 of the Customs Act must be applied harmoniously with those Rules, allowing later submission of the Certificate of Origin from the date of clearance. Reassessment and concessional duty under the relevant exemption notification remain subject to admissibility of the certificate and claim.
Post-clearance amendment of Bills of Entry may support preferential tariff claims under the India-Japan CEPA where a Certificate of Origin is issued retrospectively. Appendix-A to Annexure-2 of the CEPA Rules permits an importer lacking the certificate at importation to seek refund of excess duty after producing the certificate and supporting documents. Section 149 of the Customs Act must be applied harmoniously with those Rules, allowing later submission of the Certificate of Origin from the date of clearance. Reassessment and concessional duty under the relevant exemption notification remain subject to admissibility of the certificate and claim.
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