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...
Preferential customs-duty exemption under the Indo-Thailand Free Trade Agreement depends on compliance with the prescribed process for verifying a Certificate of Origin under the Interim Rules of Origin. The text states that Revenue did not follow the procedure in Notification No. 101/2004-Cus. (N.T.) before challenging the certificate's credibility. It therefore records that denial of exemption under Notification No. 85/2004-Cus. was unsustainable, as was the consequential penalty for alleged improper import. The impugned order was set aside and the appeals were allowed with consequential relief.
Preferential customs-duty exemption under the Indo-Thailand Free Trade Agreement depends on compliance with the prescribed process for verifying a Certificate of Origin under the Interim Rules of Origin. The text states that Revenue did not follow the procedure in Notification No. 101/2004-Cus. (N.T.) before challenging the certificate's credibility. It therefore records that denial of exemption under Notification No. 85/2004-Cus. was unsustainable, as was the consequential penalty for alleged improper import. The impugned order was set aside and the appeals were allowed with consequential relief.
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