Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Interpretation of statute - Section 2(26) of Customs Act - Scope of the term Importer - High Sea Sale - Adjudicating authority treated the appellant neither the importer not the owner - department cannot self assign to itself the duty of declaring bad in law the certificate issued to the importer by Ministry of Renewable Energy or decide title of the goods, even when no one is disputing ownership. And existence or otherwise of High Sea Sales Agreement makes no difference under Section 2 (26) of the Customs Act, 1962 regarding documented and claimed “Importer”. - AT
Interpretation of statute - Section 2(26) of Customs Act - Scope of the term Importer - High Sea Sale - Adjudicating authority treated the appellant neither the importer not the owner - department cannot self assign to itself the duty of declaring bad in law the certificate issued to the importer by Ministry of Renewable Energy or decide title of the goods, even when no one is disputing ownership. And existence or otherwise of High Sea Sales Agreement makes no difference under Section 2 (26) of the Customs Act, 1962 regarding documented and claimed “Importer”. - AT
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