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...
Penalties for facilitating alleged fraudulent exports were held unsustainable where the Revenue failed to produce cogent, independent or corroborative evidence of the customs broker's conscious involvement in overvaluation or wrongful IGST refund claims. The Tribunal held that mere suspicion, conjecture, presumptions, or the fact that documents passed through intermediaries could not justify penal action. It followed its earlier decision on substantially similar facts and found no material distinction or contrary precedent, so the penalties under Sections 114(iii) and 114AA were set aside.
Penalties for facilitating alleged fraudulent exports were held unsustainable where the Revenue failed to produce cogent, independent or corroborative evidence of the customs broker's conscious involvement in overvaluation or wrongful IGST refund claims. The Tribunal held that mere suspicion, conjecture, presumptions, or the fact that documents passed through intermediaries could not justify penal action. It followed its earlier decision on substantially similar facts and found no material distinction or contrary precedent, so the penalties under Sections 114(iii) and 114AA were set aside.
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