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...
For capital goods warehoused for manufacture or other operations, the requirement that goods be "intended for use" does not require actual installation or use in the warehouse. The notes distinguish intended use from actual use and state that, where imported goods were undisputedly intended for manufacturing operations, their later clearance for home consumption without use did not by itself attract interest on deferred customs duty. On that basis, the interest demand was treated as unsustainable, the challenged order was set aside, and consequential relief followed.
For capital goods warehoused for manufacture or other operations, the requirement that goods be "intended for use" does not require actual installation or use in the warehouse. The notes distinguish intended use from actual use and state that, where imported goods were undisputedly intended for manufacturing operations, their later clearance for home consumption without use did not by itself attract interest on deferred customs duty. On that basis, the interest demand was treated as unsustainable, the challenged order was set aside, and consequential relief followed.
Note: It is a system-generated summary and is for quick reference only.
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