Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Imported inputs/parts for manufacturing cellular mobile phones in a bonded warehouse were examined for simultaneous eligibility of exemption under N/N 57/2017-Cus (IGCR) and duty deferment under the MOOWR scheme, and for the treatment of manufacturing waste/scrap. It was held that IGCR benefits can be availed along with MOOWR, provided all conditions under the notification and IGCR Rules (including time limits and end-use compliance) are strictly met in addition to MOOWR requirements. However, disposal of waste/refuse generated in a MOOWR unit is governed exclusively by s.65(2) of the Customs Act read with MOOWR Regulations; duty neutrality applies on export of finished goods if linked waste is destroyed or cleared on duty, while home consumption attracts duty on finished goods and input-content in waste. - AAR
Imported inputs/parts for manufacturing cellular mobile phones in a bonded warehouse were examined for simultaneous eligibility of exemption under N/N 57/2017-Cus (IGCR) and duty deferment under the MOOWR scheme, and for the treatment of manufacturing waste/scrap. It was held that IGCR benefits can be availed along with MOOWR, provided all conditions under the notification and IGCR Rules (including time limits and end-use compliance) are strictly met in addition to MOOWR requirements. However, disposal of waste/refuse generated in a MOOWR unit is governed exclusively by s.65(2) of the Customs Act read with MOOWR Regulations; duty neutrality applies on export of finished goods if linked waste is destroyed or cleared on duty, while home consumption attracts duty on finished goods and input-content in waste. - AAR
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