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...
Notification No. 25/2023-Cus exempts non-sensitive inputs imported against a valid DFIA without requiring correlation of technical characteristics, quality or specifications, provided the goods match the endorsed description and satisfy the value and quantity limits in the authorisation. The exemption is confined to strict compliance with the DFIA licence, relevant SION norms and attached conditions; Customs must assess imports exactly as authorised, without adding to or diluting those terms. Where SION prescribes an actual user condition, the exemption is unavailable if that condition is breached. Conditions embedded in the DFIA scheme and licence sheet remain legally effective under the policy framework.
Notification No. 25/2023-Cus exempts non-sensitive inputs imported against a valid DFIA without requiring correlation of technical characteristics, quality or specifications, provided the goods match the endorsed description and satisfy the value and quantity limits in the authorisation. The exemption is confined to strict compliance with the DFIA licence, relevant SION norms and attached conditions; Customs must assess imports exactly as authorised, without adding to or diluting those terms. Where SION prescribes an actual user condition, the exemption is unavailable if that condition is breached. Conditions embedded in the DFIA scheme and licence sheet remain legally effective under the policy framework.
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