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...
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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