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...
Duty-free inputs common to finished goods and capital goods may be used for captive manufacture within a 100% Export Oriented Unit where capital goods are accounted for and bonded. Liability arises if those capital goods are cleared outside the unit, or upon debonding or exit from the scheme. The admitted application of this clarification resolved the dispute over inputs used in such manufacture, resulting in quashing of the seizure memoranda and show-cause notice, refund of deposits, and cancellation of the bank guarantee. Interest on the refund remained open for determination in accordance with law.
Duty-free inputs common to finished goods and capital goods may be used for captive manufacture within a 100% Export Oriented Unit where capital goods are accounted for and bonded. Liability arises if those capital goods are cleared outside the unit, or upon debonding or exit from the scheme. The admitted application of this clarification resolved the dispute over inputs used in such manufacture, resulting in quashing of the seizure memoranda and show-cause notice, refund of deposits, and cancellation of the bank guarantee. Interest on the refund remained open for determination in accordance with law.
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