Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
An importer may claim entitlement under Notification No.99/2011-CUS (SAFTA exemption) belatedly, including post-clearance or at appellate stage, provided the notification conditions are met; lack of claim at initial self-assessment does not create estoppel and authorities must grant admissible legal benefits when eligibility is shown. Where imports were provisionally assessed, provisional clearance does not bar reconsideration; the proper remedial step is remand to the original authority to examine SAFTA certificates and, if admissible, grant the exemption while finalizing provisional assessments. Denial solely because the claim was not made at clearance or was premature is unsustainable.
An importer may claim entitlement under Notification No.99/2011-CUS (SAFTA exemption) belatedly, including post-clearance or at appellate stage, provided the notification conditions are met; lack of claim at initial self-assessment does not create estoppel and authorities must grant admissible legal benefits when eligibility is shown. Where imports were provisionally assessed, provisional clearance does not bar reconsideration; the proper remedial step is remand to the original authority to examine SAFTA certificates and, if admissible, grant the exemption while finalizing provisional assessments. Denial solely because the claim was not made at clearance or was premature is unsustainable.
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