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...
Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
