Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Regularization of bona fide default under the Foreign Trade Policy provisions operates to revise and restate the export obligation (EO) in the Advance Authorizations, and the quantum of EO is a licensing authority determination; consequently fulfilment of EO as accepted by the licensing authority precludes Customs from treating conditions in Customs notifications as separately violated. An Export Obligation Discharge Certificate (EODC) is conclusive evidence of EO fulfilment for recovery purposes and, where bonds securing authorizations have been cancelled, demands under Customs Act provision for recovery cannot be enforced, negating duty, interest, penalty and confiscation.
Regularization of bona fide default under the Foreign Trade Policy provisions operates to revise and restate the export obligation (EO) in the Advance Authorizations, and the quantum of EO is a licensing authority determination; consequently fulfilment of EO as accepted by the licensing authority precludes Customs from treating conditions in Customs notifications as separately violated. An Export Obligation Discharge Certificate (EODC) is conclusive evidence of EO fulfilment for recovery purposes and, where bonds securing authorizations have been cancelled, demands under Customs Act provision for recovery cannot be enforced, negating duty, interest, penalty and confiscation.
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