Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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This instruction clarifies the retrospective issuance of Certificates of Origin (COOs) under the India-UAE Comprehensive Economic Partnership Agreement (CEPA). Rule 15(11) permits retrospective issuance of COOs in exceptional cases within 12 months of shipment, with reasons recorded by the issuing authority. Rule 21(3) allows importers to claim refund of excess duties if preferential treatment was not initially extended despite the product qualifying as originating. Minor discrepancies like typing errors should not invalidate COOs if authenticity and accuracy are not affected. The intent is to extend substantive trade agreement benefits without nullifying legal entitlements due to procedural discrepancies, unless originating status is doubtful. Customs formations are instructed to sensitize accordingly.
This instruction clarifies the retrospective issuance of Certificates of Origin (COOs) under the India-UAE Comprehensive Economic Partnership Agreement (CEPA). Rule 15(11) permits retrospective issuance of COOs in exceptional cases within 12 months of shipment, with reasons recorded by the issuing authority. Rule 21(3) allows importers to claim refund of excess duties if preferential treatment was not initially extended despite the product qualifying as originating. Minor discrepancies like typing errors should not invalidate COOs if authenticity and accuracy are not affected. The intent is to extend substantive trade agreement benefits without nullifying legal entitlements due to procedural discrepancies, unless originating status is doubtful. Customs formations are instructed to sensitize accordingly.
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