Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
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