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...
CESTAT allowed appeal concerning disputed classification of imported internal combustion engines under transferrable DFIA license. Per N/N. 98/2009-Cus, customs duty exemption requires only that imported materials match authorization's description, value, and quantity. While export item aligned with SION Category C969, the authorization contained no explicit import restrictions or category specifications. CBEC Circular 46/2007 confirms correlation between inputs and exports needed only for specific products under para 4.55.3 of Handbook. Tribunal held appellant not required to correlate imports with original licensee's exports, as authorization language imposed no restrictions limiting engine imports to specific export-related uses. Impugned order set aside.
CESTAT allowed appeal concerning disputed classification of imported internal combustion engines under transferrable DFIA license. Per N/N. 98/2009-Cus, customs duty exemption requires only that imported materials match authorization's description, value, and quantity. While export item aligned with SION Category C969, the authorization contained no explicit import restrictions or category specifications. CBEC Circular 46/2007 confirms correlation between inputs and exports needed only for specific products under para 4.55.3 of Handbook. Tribunal held appellant not required to correlate imports with original licensee's exports, as authorization language imposed no restrictions limiting engine imports to specific export-related uses. Impugned order set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
