International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
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