Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Benefit under EPCG Scheme denied - The first part of the definition of capital goods uses the term ‘means’. The term ‘means’ is exhaustive in nature and is meant to cover all the items mentioned therein, namely, plant, machinery, equipment or accessories, as ordinarily understood, required for the manufacture or production, either directly or indirectly of goods. Refractory bricks are clearly accessories required for lining of the furnace, and hence indirectly used for manufacture of finished goods by the appellants. The use of the expression ‘ refractories for initial lining’ in the inclusive part of the definition of capital goods does not in any way restrict the meaning of the terms used in the ‘means’ part of the definition. - AT
Benefit under EPCG Scheme denied - The first part of the definition of capital goods uses the term ‘means’. The term ‘means’ is exhaustive in nature and is meant to cover all the items mentioned therein, namely, plant, machinery, equipment or accessories, as ordinarily understood, required for the manufacture or production, either directly or indirectly of goods. Refractory bricks are clearly accessories required for lining of the furnace, and hence indirectly used for manufacture of finished goods by the appellants. The use of the expression ‘ refractories for initial lining’ in the inclusive part of the definition of capital goods does not in any way restrict the meaning of the terms used in the ‘means’ part of the definition. - AT
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