Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Goods falling under sub-heading 16010000 were outside Notification No. 125/2011-Cus. because the annexure expressly excluded heading/sub-heading 160100, so the original exemption claim failed. The alternate claim under Notification No. 26/2000-Cus. was also rejected because a conditional exemption required supporting documents, and new material could not be introduced for the first time in appeal without compliance with the procedure for additional evidence under Rule 23. The limitation objection was denied as the one-year period under Section 28 of the Customs Act ran from the end of the month of filing of the bill of entry, making the demand notice timely.
Goods falling under sub-heading 16010000 were outside Notification No. 125/2011-Cus. because the annexure expressly excluded heading/sub-heading 160100, so the original exemption claim failed. The alternate claim under Notification No. 26/2000-Cus. was also rejected because a conditional exemption required supporting documents, and new material could not be introduced for the first time in appeal without compliance with the procedure for additional evidence under Rule 23. The limitation objection was denied as the one-year period under Section 28 of the Customs Act ran from the end of the month of filing of the bill of entry, making the demand notice timely.
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