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...
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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