Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Notification 52/2003-Cus dated 31.03.2003 governs the re-import of goods after export. Sr. No. 14 allows re-import for repair/reconditioning within 3/7 years, irrespective of buyer's rejection, while Sr. No. 15 permits re-import within 1 year if rejected by buyer. The Tribunal held that Sr. No. 14 applies if goods are re-imported for repair/reconditioning for re-export, even if rejected by buyer, subject to time limits. For goods not in Annexure VII, the 3-year limit under Sr. No. 14 applies, not the 1-year limit under Sr. No. 15. Rejecting the department's view, the Tribunal allowed the benefit of Notification 52/2003 (Sr. No. 14) on the re-imported goods.
Notification 52/2003-Cus dated 31.03.2003 governs the re-import of goods after export. Sr. No. 14 allows re-import for repair/reconditioning within 3/7 years, irrespective of buyer's rejection, while Sr. No. 15 permits re-import within 1 year if rejected by buyer. The Tribunal held that Sr. No. 14 applies if goods are re-imported for repair/reconditioning for re-export, even if rejected by buyer, subject to time limits. For goods not in Annexure VII, the 3-year limit under Sr. No. 14 applies, not the 1-year limit under Sr. No. 15. Rejecting the department's view, the Tribunal allowed the benefit of Notification 52/2003 (Sr. No. 14) on the re-imported goods.
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TaxTMI 
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