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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AAR held that, under the MOOWR scheme, warehoused aluminium frames imported prior to 27.09.2024 but cleared for home consumption on or after that date attract Anti-Dumping Duty pursuant to N/N. 16/2024-Customs (ADD). Applying Section 15(1)(b) of the Customs Act read with Section 9A(8) of the Customs Tariff Act, the determinative date for the rate of ADD on warehoused goods is the date of presentation of the ex-bond Bill of Entry, not the date of warehousing. ADD is to be treated on par with other customs duties. The applicant's contention that only initially deferred duties (BCD, SWS, IGST) are payable at ex-bond was rejected.
AAR held that, under the MOOWR scheme, warehoused aluminium frames imported prior to 27.09.2024 but cleared for home consumption on or after that date attract Anti-Dumping Duty pursuant to N/N. 16/2024-Customs (ADD). Applying Section 15(1)(b) of the Customs Act read with Section 9A(8) of the Customs Tariff Act, the determinative date for the rate of ADD on warehoused goods is the date of presentation of the ex-bond Bill of Entry, not the date of warehousing. ADD is to be treated on par with other customs duties. The applicant's contention that only initially deferred duties (BCD, SWS, IGST) are payable at ex-bond was rejected.
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