Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Export Obligation Discharge Certificate issuance after submission of required particulars establishes fulfilment of EPCG authorisation conditions, including the export obligation and actual-user requirement for concessional-duty car imports. Where non-production of the certificate in earlier proceedings was beyond the importer's control, its subsequent grant removes the legal basis for alleging non-compliance. Consequently, customs duty demand, confiscation of the imported car, redemption fine and penalties for the alleged breach of EPCG conditions cannot be sustained.
Export Obligation Discharge Certificate issuance after submission of required particulars establishes fulfilment of EPCG authorisation conditions, including the export obligation and actual-user requirement for concessional-duty car imports. Where non-production of the certificate in earlier proceedings was beyond the importer's control, its subsequent grant removes the legal basis for alleging non-compliance. Consequently, customs duty demand, confiscation of the imported car, redemption fine and penalties for the alleged breach of EPCG conditions cannot be sustained.
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