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...
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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