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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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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