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...
Section 28-I(2) bars admission of an advance-ruling application when the question raised is the same as one already decided by a Court or Appellate Tribunal. The classification of plain oven-roasted areca nuts was treated as settled by a binding High Court decision, so the classification issue could not be reconsidered through advance ruling. The notes further explain that the statutory scheme does not permit partial rejection of an application: although the related customs-duty exemption question was not independently covered, it could not be retained for separate determination. Accordingly, the applications were rejected in full without rulings on either issue.
Section 28-I(2) bars admission of an advance-ruling application when the question raised is the same as one already decided by a Court or Appellate Tribunal. The classification of plain oven-roasted areca nuts was treated as settled by a binding High Court decision, so the classification issue could not be reconsidered through advance ruling. The notes further explain that the statutory scheme does not permit partial rejection of an application: although the related customs-duty exemption question was not independently covered, it could not be retained for separate determination. Accordingly, the applications were rejected in full without rulings on either issue.
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