Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Clause (ii) of Condition No. 6 in the exemption notification, requiring exports to be backed by an irrevocable letter of credit opened before 25.08.2023, was held inapplicable where no letter of credit existed, since export through LoC is not statutorily mandatory and the condition presupposes an LoC-based transaction. Reading clauses (i) and (ii) conjunctively merely due to the word "and" was rejected; conditions must be construed contextually to avoid absurdity, and procedural requirements cannot defeat substantive entitlement where the notification's protective object is met. As the exporter satisfied clause (i) and realised export proceeds through recognised modes, exemption was granted and refund with interest was ordered within eight weeks - HC
Clause (ii) of Condition No. 6 in the exemption notification, requiring exports to be backed by an irrevocable letter of credit opened before 25.08.2023, was held inapplicable where no letter of credit existed, since export through LoC is not statutorily mandatory and the condition presupposes an LoC-based transaction. Reading clauses (i) and (ii) conjunctively merely due to the word "and" was rejected; conditions must be construed contextually to avoid absurdity, and procedural requirements cannot defeat substantive entitlement where the notification's protective object is met. As the exporter satisfied clause (i) and realised export proceeds through recognised modes, exemption was granted and refund with interest was ordered within eight weeks - HC
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