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...
An actual user condition cannot be imposed on imports under a transferable post-export DFIA through a mere public notice; the scheme is distinct from advance authorisation and does not carry an inbuilt actual-user restriction for the transferee. The Tribunal's power to test the vires of statutory or subordinate legislation within its field is affirmed, and such a challenge is not excluded in a customs dispute. For expired DFIAs, where the licences remained unutilised because the benefit had been denied, Customs is to issue a factual certificate to DGFT so revalidation may be considered by the competent authority.
An actual user condition cannot be imposed on imports under a transferable post-export DFIA through a mere public notice; the scheme is distinct from advance authorisation and does not carry an inbuilt actual-user restriction for the transferee. The Tribunal's power to test the vires of statutory or subordinate legislation within its field is affirmed, and such a challenge is not excluded in a customs dispute. For expired DFIAs, where the licences remained unutilised because the benefit had been denied, Customs is to issue a factual certificate to DGFT so revalidation may be considered by the competent authority.
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