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/s 114(iii) and 114AA of the Customs Act - respondents categorically stated that only the corrigendum was served on them without the show cause notice - Penalty could not have been imposed upon the two respondents if opportunity was not provided to the two respondents to file a reply to the show cause notice. This apart, the show cause notice also does not contain any allegation against the two respondents. - AT
Levy of penalty u/s 114(iii) and 114AA of the Customs Act - respondents categorically stated that only the corrigendum was served on them without the show cause notice - Penalty could not have been imposed upon the two respondents if opportunity was not provided to the two respondents to file a reply to the show cause notice. This apart, the show cause notice also does not contain any allegation against the two respondents. - AT
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