Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Export Obligation Discharge Certificate issuance after submission of required particulars establishes fulfilment of EPCG authorisation conditions, including the export obligation and actual-user requirement for concessional-duty car imports. Where non-production of the certificate in earlier proceedings was beyond the importer's control, its subsequent grant removes the legal basis for alleging non-compliance. Consequently, customs duty demand, confiscation of the imported car, redemption fine and penalties for the alleged breach of EPCG conditions cannot be sustained.
Export Obligation Discharge Certificate issuance after submission of required particulars establishes fulfilment of EPCG authorisation conditions, including the export obligation and actual-user requirement for concessional-duty car imports. Where non-production of the certificate in earlier proceedings was beyond the importer's control, its subsequent grant removes the legal basis for alleging non-compliance. Consequently, customs duty demand, confiscation of the imported car, redemption fine and penalties for the alleged breach of EPCG conditions cannot be sustained.
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