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...
SION - starch slurry - maize - manufacturing of liquid glucose concentrate (food grade) - Recovery of customs duty foregone on the inputs allowed to be imported under 7 DFIA licences - In the present case, the immediate parent material was starch slurry i.e. starch and not maize and therefore case of the department that SION E76 was the correct norm cannot be sustained. Since the immediate parent material for manufacturing the exported goods was starch falling under SION E22 , it is clear that the Starch was the correctly applicable SION. - AT
SION - starch slurry - maize - manufacturing of liquid glucose concentrate (food grade) - Recovery of customs duty foregone on the inputs allowed to be imported under 7 DFIA licences - In the present case, the immediate parent material was starch slurry i.e. starch and not maize and therefore case of the department that SION E76 was the correct norm cannot be sustained. Since the immediate parent material for manufacturing the exported goods was starch falling under SION E22 , it is clear that the Starch was the correctly applicable SION. - AT
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