Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Seeking Conversion of shipping bills - conversion of Export Promotion Scheme from Duty Drawback (DBK) to Advance Licence - there is a clear and independent provision under section 149 that without challenging the assessment an assessee can seek amendment under shipping bill even after assessment of export documents. Moreover, the learned principal commissioner has denied the conversion only on the ground that the appellant had violated condition prescribed under para 3 (e) of Circular no. 36/2010-Cus dated 23.09.2010, thus condition does not get violated therefore, the revenue’s submission is not relevant. - AT
Seeking Conversion of shipping bills - conversion of Export Promotion Scheme from Duty Drawback (DBK) to Advance Licence - there is a clear and independent provision under section 149 that without challenging the assessment an assessee can seek amendment under shipping bill even after assessment of export documents. Moreover, the learned principal commissioner has denied the conversion only on the ground that the appellant had violated condition prescribed under para 3 (e) of Circular no. 36/2010-Cus dated 23.09.2010, thus condition does not get violated therefore, the revenue’s submission is not relevant. - AT
Note: It is a system-generated summary and is for quick reference only.