Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
The AAR held that it lacks jurisdiction to rule on duty drawback issues under the Customs and Central Excise Duties Drawback Rules, 2017 for goods manufactured in MOOWR premises and exported. To avail Notification No. 21/2023 exemption, filing a home consumption Bill of Entry is mandatory, and goods imported under Advance Authorization cannot be considered warehoused goods. The Applicant cannot debond capital goods imported under MOOWR using EPCG authorization or avail Notification No. 26/2023 exemption. Goods cannot be imported duty-free in MOOWR under Advance Authorization as MOOWR and private bonded warehouses have different provisions. Supply to third-party customers can be considered exports if directly exported.
The AAR held that it lacks jurisdiction to rule on duty drawback issues under the Customs and Central Excise Duties Drawback Rules, 2017 for goods manufactured in MOOWR premises and exported. To avail Notification No. 21/2023 exemption, filing a home consumption Bill of Entry is mandatory, and goods imported under Advance Authorization cannot be considered warehoused goods. The Applicant cannot debond capital goods imported under MOOWR using EPCG authorization or avail Notification No. 26/2023 exemption. Goods cannot be imported duty-free in MOOWR under Advance Authorization as MOOWR and private bonded warehouses have different provisions. Supply to third-party customers can be considered exports if directly exported.
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TaxTMI 
TaxTMI 
