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...
Compression of natural gas constitutes manufacture under Chapter Note 5 to Chapter 27 only where it is compressed for marketing as compressed natural gas. Compression undertaken solely to facilitate transportation, followed by decompression at customers' premises and sale as natural gas, does not amount to manufacture under section 2(f) of the Central Excise Act, 1944. On that basis, the excise duty demand, interest and penalties on the company, including the penalty imposed on its Chairman-CEO, were set aside.
Compression of natural gas constitutes manufacture under Chapter Note 5 to Chapter 27 only where it is compressed for marketing as compressed natural gas. Compression undertaken solely to facilitate transportation, followed by decompression at customers' premises and sale as natural gas, does not amount to manufacture under section 2(f) of the Central Excise Act, 1944. On that basis, the excise duty demand, interest and penalties on the company, including the penalty imposed on its Chairman-CEO, were set aside.
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