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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Imported goods meant for warehousing in SEZ unit are eligible for relaxation from security demanded in provisional release order for re-export. Re-export of imported goods into SEZ is not subject to customs or excise duty levy, irrespective of any alleged offense. In cases of re-export, redemption fine was set aside and minimal penalty imposed, as per precedents. SEZ operations governed by SEZ Act and Customs Act, hence no mala fide intention to evade duty can be expected. Bond for total value of goods sufficient for releasing seized goods for re-export. Judgments cited by revenue not applicable to SEZ unit or warehouse. Observation limited to provisional release for re-export only, not influencing adjudication under show cause notice.
Imported goods meant for warehousing in SEZ unit are eligible for relaxation from security demanded in provisional release order for re-export. Re-export of imported goods into SEZ is not subject to customs or excise duty levy, irrespective of any alleged offense. In cases of re-export, redemption fine was set aside and minimal penalty imposed, as per precedents. SEZ operations governed by SEZ Act and Customs Act, hence no mala fide intention to evade duty can be expected. Bond for total value of goods sufficient for releasing seized goods for re-export. Judgments cited by revenue not applicable to SEZ unit or warehouse. Observation limited to provisional release for re-export only, not influencing adjudication under show cause notice.
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