Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Advance Authorisation IGST exemption remains subject to the pre-import condition; later fulfilment of export obligation or issuance of EODCs does not erase an established breach. Imports breaching that condition must instead be regularised under the prescribed procedure, with EODCs and redemption certificates relevant to liability. IGST breach must be quantified Bill of Entry-wise and raw material-wise by correlating imports, exports and chronology, while accounting for permitted clubbing of authorisations. The IGST demand requires fresh quantification on that basis. For the relevant period, recovery provisions did not independently authorise interest, confiscation, redemption fine or penalty for the IGST liability; those consequential liabilities were set aside, including interest on re-quantified IGST.
Advance Authorisation IGST exemption remains subject to the pre-import condition; later fulfilment of export obligation or issuance of EODCs does not erase an established breach. Imports breaching that condition must instead be regularised under the prescribed procedure, with EODCs and redemption certificates relevant to liability. IGST breach must be quantified Bill of Entry-wise and raw material-wise by correlating imports, exports and chronology, while accounting for permitted clubbing of authorisations. The IGST demand requires fresh quantification on that basis. For the relevant period, recovery provisions did not independently authorise interest, confiscation, redemption fine or penalty for the IGST liability; those consequential liabilities were set aside, including interest on re-quantified IGST.
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