Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The note addresses re export permission conditioned on payment of a redemption fine and the statutory limitation for exercising that option. It explains that under the applicable statutory scheme the option to redeem lapses if the fine is not paid within the prescribed 120 day period and no appeal is pending, and that the prescribed appeal window (60 days plus 30 days extension) was not availed. Ignorance of the limitation provision was rejected. Operative effect: the redemption option was held to have lapsed, the writ was dismissed on merits, and the paid redemption fine was ordered refunded.
The note addresses re export permission conditioned on payment of a redemption fine and the statutory limitation for exercising that option. It explains that under the applicable statutory scheme the option to redeem lapses if the fine is not paid within the prescribed 120 day period and no appeal is pending, and that the prescribed appeal window (60 days plus 30 days extension) was not availed. Ignorance of the limitation provision was rejected. Operative effect: the redemption option was held to have lapsed, the writ was dismissed on merits, and the paid redemption fine was ordered refunded.
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