Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Export duty on iron ore fines had to be assessed with reference to the taxable event and the law in force on the date of export, so the later amendment could not be applied retrospectively to exports made earlier. The Court held that Fe content for the relevant shipping bills had to be determined on WMT basis, in line with Circular No. 04/2012-Cus., which remained binding on the Department while operative. The adjudicating authority erred in proceeding on DMT basis and in treating alleged fraud or DMT pricing as grounds to ignore the circular. The order was set aside and the matter remitted for fresh adjudication after hearing and confrontation of relied-upon material.
Export duty on iron ore fines had to be assessed with reference to the taxable event and the law in force on the date of export, so the later amendment could not be applied retrospectively to exports made earlier. The Court held that Fe content for the relevant shipping bills had to be determined on WMT basis, in line with Circular No. 04/2012-Cus., which remained binding on the Department while operative. The adjudicating authority erred in proceeding on DMT basis and in treating alleged fraud or DMT pricing as grounds to ignore the circular. The order was set aside and the matter remitted for fresh adjudication after hearing and confrontation of relied-upon material.
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