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...
Drawback Brand Rate and Special Brand Rate applications filed after the initial period but within twelve months of the Let Export Order require liberal consideration because the drawback scheme is beneficial in nature. A narrow or technical approach to delay within the statutorily extendable period is inappropriate. Delay in the relevant applications was condoned, and the applications were remanded for consideration on merits and fixation of the applicable drawback rate in accordance with law, with consequential relief.
Drawback Brand Rate and Special Brand Rate applications filed after the initial period but within twelve months of the Let Export Order require liberal consideration because the drawback scheme is beneficial in nature. A narrow or technical approach to delay within the statutorily extendable period is inappropriate. Delay in the relevant applications was condoned, and the applications were remanded for consideration on merits and fixation of the applicable drawback rate in accordance with law, with consequential relief.
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