Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Under the Indo-Thai Free Trade Agreement, Indian customs authorities could not disregard Certificates of Origin once the Thai authorities had confirmed their authenticity and issuance by the Department of Foreign Trade, Thailand. The decision treats that foreign certification as conclusive for concessional duty purposes and bars an independent Indian enquiry that would undermine the Interim Rules of Origin. A statement recorded from the importer under the Customs Act could not affect the authenticity of the certificates. The Tribunal's view was upheld, and the Revenue's challenge failed because no substantial question of law arose.
Under the Indo-Thai Free Trade Agreement, Indian customs authorities could not disregard Certificates of Origin once the Thai authorities had confirmed their authenticity and issuance by the Department of Foreign Trade, Thailand. The decision treats that foreign certification as conclusive for concessional duty purposes and bars an independent Indian enquiry that would undermine the Interim Rules of Origin. A statement recorded from the importer under the Customs Act could not affect the authenticity of the certificates. The Tribunal's view was upheld, and the Revenue's challenge failed because no substantial question of law arose.
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