Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
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