Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Para 5.17(a) of the HBP (FTP 2023) permits reduction of Annual Average Export Obligation (EO) for EPCG authorisations where a sector/product group records over 5% decline in exports in 2024-25 versus 2023-24; Regional Authorities must re-fix EOs accordingly and endorse reductions in licence files and amendment sheets. Regional Offices must, when considering EO discharge or shortfall actions, apply earlier policy circulars referenced and account for those precedents before issuing demand notices or EODC; this requirement must be included in the EODC check-sheet. Issued with DGFT approval.
Para 5.17(a) of the HBP (FTP 2023) permits reduction of Annual Average Export Obligation (EO) for EPCG authorisations where a sector/product group records over 5% decline in exports in 2024-25 versus 2023-24; Regional Authorities must re-fix EOs accordingly and endorse reductions in licence files and amendment sheets. Regional Offices must, when considering EO discharge or shortfall actions, apply earlier policy circulars referenced and account for those precedents before issuing demand notices or EODC; this requirement must be included in the EODC check-sheet. Issued with DGFT approval.
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