Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
RoDTEP and RoSCTL benefits are clarified to follow the same treatment as duty drawback where export realisation is short: remission or rebate may be allowed on FOB value without deducting agency commission and foreign bank charges if those deductions stay within the overall 12.5% FOB limit; if they exceed that limit, the excess must be deducted from FOB value for benefit computation. Compensation received from ECGC for short realisation of export proceeds may be treated as receipt of sale proceeds, so remission or rebate under RoDTEP and RoSCTL need not be recovered, provided RBI writes off realisation on merits and the exporter produces the required certificate from the concerned Foreign Mission of India.
RoDTEP and RoSCTL benefits are clarified to follow the same treatment as duty drawback where export realisation is short: remission or rebate may be allowed on FOB value without deducting agency commission and foreign bank charges if those deductions stay within the overall 12.5% FOB limit; if they exceed that limit, the excess must be deducted from FOB value for benefit computation. Compensation received from ECGC for short realisation of export proceeds may be treated as receipt of sale proceeds, so remission or rebate under RoDTEP and RoSCTL need not be recovered, provided RBI writes off realisation on merits and the exporter produces the required certificate from the concerned Foreign Mission of India.
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