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...
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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.
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