Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Process amounting to manufacture or not - activity of “labelling or relabeling, declaration by affixing fresh Maximum Retail Price (MRP) stickers” on each unit pack, by altering the retail price stickers already affixed on the watches - The tribunal concluded that relabeling and affixing new MRP stickers do not amount to manufacture. It relied on precedents stating that such activities, not enhancing the goods' marketability, do not meet the manufacture criteria under the Excise Act. - The tribunal supported the appellants' view that Section 2(f)(iii) does not apply to goods manufactured under ABE, as applying the concept of deemed manufacture to such goods would counteract the exemption's intent.
Process amounting to manufacture or not - activity of “labelling or relabeling, declaration by affixing fresh Maximum Retail Price (MRP) stickers” on each unit pack, by altering the retail price stickers already affixed on the watches - The tribunal concluded that relabeling and affixing new MRP stickers do not amount to manufacture. It relied on precedents stating that such activities, not enhancing the goods' marketability, do not meet the manufacture criteria under the Excise Act. - The tribunal supported the appellants' view that Section 2(f)(iii) does not apply to goods manufactured under ABE, as applying the concept of deemed manufacture to such goods would counteract the exemption's intent.
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