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...
Where a customs adjudication order is challenged after expiry of the statutory appeal period, writ jurisdiction should not be invoked when an efficacious appellate remedy existed and was not availed within the prescribed or condonable time. The natural justice exception did not assist the petitioners because they showed no compelling reason for missing the appeal, did not seek condonation, and did not explain the delay in approaching the appellate forum or the writ court. The writ petitions were therefore held not maintainable and rejected.
Where a customs adjudication order is challenged after expiry of the statutory appeal period, writ jurisdiction should not be invoked when an efficacious appellate remedy existed and was not availed within the prescribed or condonable time. The natural justice exception did not assist the petitioners because they showed no compelling reason for missing the appeal, did not seek condonation, and did not explain the delay in approaching the appellate forum or the writ court. The writ petitions were therefore held not maintainable and rejected.
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