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...
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
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