Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Exemption under Notification No. 50/2017-Cus was denied because the goods were found suitable for use in motor vehicles, and the exclusion clause was read strictly without adding a requirement that the goods be directly fitted into the vehicle. The Tribunal accepted that motors and sensors used solely in manufacture of automotive systems could fall within the exclusion, so the concessional customs duty benefit was unavailable. Classification of pressure transducers/sensors under CTH 90318000 was sustained because the importer had consistently declared that heading and no dispute on classification was raised in the show cause notice for the relevant period. Interest and penalty on the IGST component were set aside as the amended levy applied prospectively from 16.08.2024.
Exemption under Notification No. 50/2017-Cus was denied because the goods were found suitable for use in motor vehicles, and the exclusion clause was read strictly without adding a requirement that the goods be directly fitted into the vehicle. The Tribunal accepted that motors and sensors used solely in manufacture of automotive systems could fall within the exclusion, so the concessional customs duty benefit was unavailable. Classification of pressure transducers/sensors under CTH 90318000 was sustained because the importer had consistently declared that heading and no dispute on classification was raised in the show cause notice for the relevant period. Interest and penalty on the IGST component were set aside as the amended levy applied prospectively from 16.08.2024.
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