Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
