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...
Concessional duty under Sl. No. 5D(b) of Notfn. 57/2017-Cus for "inputs and parts for use in manufacture" was held applicable to imported inputs/parts placed in the display assembly manufacturing line even if they are subsequently damaged or scrapped and do not form part of the finished display assembly, since the phrase covers goods used in the manufacturing process and not merely those incorporated in the final product. IGCR provisions on defective/unutilized goods were treated as addressing goods defective at import and not restricting the notification's scope for process scrap. Benefit of exemption was thus allowed for such manufacturing scrap inputs/parts. - AAR
Concessional duty under Sl. No. 5D(b) of Notfn. 57/2017-Cus for "inputs and parts for use in manufacture" was held applicable to imported inputs/parts placed in the display assembly manufacturing line even if they are subsequently damaged or scrapped and do not form part of the finished display assembly, since the phrase covers goods used in the manufacturing process and not merely those incorporated in the final product. IGCR provisions on defective/unutilized goods were treated as addressing goods defective at import and not restricting the notification's scope for process scrap. Benefit of exemption was thus allowed for such manufacturing scrap inputs/parts. - AAR
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