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    Rectification appeal limitation runs from refusal order, while contingent-liability disclosures cannot justify disallowing unclaimed deductions.
    Arm's-length range treatment protects royalty payments within range, while evidence-based intra-group services cannot receive a nil valuation.
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Rectification or modification of an advance ruling cannot reopen...

Rectification of advance rulings cannot waive express customs exemption conditions for repair and re-export by DTA units.

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Customs October 27, 2026 Case Laws AAR
Rectification or modification of an advance ruling cannot reopen its merits or waive an express condition of a customs exemption. Exemption for imported goods repaired or refurbished and re-exported remains subject to Notification No. 134/94-Cus, including performance of prescribed operations under Section 65 of the Customs Act, 1962. A DTA unit's operational difficulty in not operating under the MOOWR scheme does not constitute a mistake apparent from the record or a legal or factual error. Alternative safeguards, conditions under other notifications, and proposed traceability measures cannot replace the governing notification's express requirement. The request to dispense with that condition was rejected, leaving the ruling operative subject to all notification conditions.

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Acts Income Tax