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...
Provisional release of seized imported Multi-Functional Devices was directed subject to payment of the enhanced duty as quantified, furnishing a bank guarantee for 10% of the total price, and maintenance of transaction details if the goods were later sold. HC treated the matter as comparable to earlier petitions where conditional release had been ordered, and left customs adjudication to proceed independently on merits. Any request for waiver of demurrage was to be considered objectively, and the adjudicating authority was to decide uninfluenced by the interim release.
Provisional release of seized imported Multi-Functional Devices was directed subject to payment of the enhanced duty as quantified, furnishing a bank guarantee for 10% of the total price, and maintenance of transaction details if the goods were later sold. HC treated the matter as comparable to earlier petitions where conditional release had been ordered, and left customs adjudication to proceed independently on merits. Any request for waiver of demurrage was to be considered objectively, and the adjudicating authority was to decide uninfluenced by the interim release.
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