Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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CBIC clarified that All Industry Rate (AIR) of duty drawback cannot be denied or reduced for export goods manufactured using partially non-duty paid or concessionally duty paid inputs. The rates are determined based on weighted average duties paid on inputs across a representative cross-section of exporters. Field formations are not authorized to investigate whether exempted inputs were used in manufacturing export goods. This reaffirms Board Circular No. 19/2005-Customs position that AIR calculation considers average duty patterns, making individual input duty status irrelevant for drawback eligibility. The instruction ensures uniform application of drawback rules across customs jurisdictions.
CBIC clarified that All Industry Rate (AIR) of duty drawback cannot be denied or reduced for export goods manufactured using partially non-duty paid or concessionally duty paid inputs. The rates are determined based on weighted average duties paid on inputs across a representative cross-section of exporters. Field formations are not authorized to investigate whether exempted inputs were used in manufacturing export goods. This reaffirms Board Circular No. 19/2005-Customs position that AIR calculation considers average duty patterns, making individual input duty status irrelevant for drawback eligibility. The instruction ensures uniform application of drawback rules across customs jurisdictions.
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