Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
Liability to pay customs duty for goods imported under Special Advance Authorization was remitted for fresh consideration because the impugned order was non-speaking and did not address the petitioners contention that customs duty was not payable in view of Special Advance Authorization and a Customs Notification dated 01.04.2023; the respondent is directed to afford a personal hearing, decide on merits in accordance with law within four weeks, and, if the petitioner succeeds, consider waiver of detention and demurrage charges in accordance with law.
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