Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Maintainability of advance ruling application questioned due to pending classification issue before Customs Officer for 13 imported products used in Lithium-ion cell manufacturing. Advance ruling definition u/s 28E allows rulings on pre-importation questions, but Customs Authorities have issued rulings on post-importation queries for consistency and facilitation. Section 28 provides for pre-notice consultation and duty payment by importer before notice for short-levy. Applicant initiated reassessment process, rendering advance ruling application liable for rejection as classification issue pending before Customs Officer. Advance ruling application dismissed.
Maintainability of advance ruling application questioned due to pending classification issue before Customs Officer for 13 imported products used in Lithium-ion cell manufacturing. Advance ruling definition u/s 28E allows rulings on pre-importation questions, but Customs Authorities have issued rulings on post-importation queries for consistency and facilitation. Section 28 provides for pre-notice consultation and duty payment by importer before notice for short-levy. Applicant initiated reassessment process, rendering advance ruling application liable for rejection as classification issue pending before Customs Officer. Advance ruling application dismissed.
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