Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Value addition - Duty-free import of gold - Replenishment of gold under the ‘replenishment scheme’ from DIL against export of gold jewellery - The tribunal concluded that the manufacturing process was indeed fully mechanized, dismissing the department's claim of a semi-mechanized process. This determination was crucial as it affected the applicable wastage norms and minimum value addition required under the FTP. - Regarding Value Addition Calculation, the tribunal, referencing FTP provisions and clarifications from the Director-General of Foreign Trade (DGFT), sided with the appellants. It was held that the calculation method adopted by the department was incorrect, and the appellants had indeed met the value addition criteria as per the correct interpretation of FTP guidelines.
Value addition - Duty-free import of gold - Replenishment of gold under the ‘replenishment scheme’ from DIL against export of gold jewellery - The tribunal concluded that the manufacturing process was indeed fully mechanized, dismissing the department's claim of a semi-mechanized process. This determination was crucial as it affected the applicable wastage norms and minimum value addition required under the FTP. - Regarding Value Addition Calculation, the tribunal, referencing FTP provisions and clarifications from the Director-General of Foreign Trade (DGFT), sided with the appellants. It was held that the calculation method adopted by the department was incorrect, and the appellants had indeed met the value addition criteria as per the correct interpretation of FTP guidelines.
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