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...
Levy of penalty u/r 26 - Personal penalty for abatement in evasion of duty - a plain reading of Rule 26 indicates that imposition of the penalty therein is not tied to a condition that excisable goods have to be placed under confiscation under the Act/Rules - Only, the person implicated/concerned should have the knowledge of “possible confiscation” of the impugned goods. From the facts on record, the appellant have played crucial role in commission of offence by the manufacturer. Appellant is liable to penalty under Rule 26 of the Central Excise Rules.- AT
Levy of penalty u/r 26 - Personal penalty for abatement in evasion of duty - a plain reading of Rule 26 indicates that imposition of the penalty therein is not tied to a condition that excisable goods have to be placed under confiscation under the Act/Rules - Only, the person implicated/concerned should have the knowledge of “possible confiscation” of the impugned goods. From the facts on record, the appellant have played crucial role in commission of offence by the manufacturer. Appellant is liable to penalty under Rule 26 of the Central Excise Rules.- AT
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