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 on the Director of the company - Allegation of Clandestine removal of goods - The Tribunal observed that the statement of an employee, admitting to supplying goods, did not specify quantities, values, or payments, making it insufficient as evidence. - Further, The adjudicating authority did not cross-examine the employee, as required under Section 9 (d) of the Central Excise Act, 1944. Without cross-examination, the employee's statement could not be relied upon as evidence. - No penalty - AT
Levy of penalty u/r 26 on the Director of the company - Allegation of Clandestine removal of goods - The Tribunal observed that the statement of an employee, admitting to supplying goods, did not specify quantities, values, or payments, making it insufficient as evidence. - Further, The adjudicating authority did not cross-examine the employee, as required under Section 9 (d) of the Central Excise Act, 1944. Without cross-examination, the employee's statement could not be relied upon as evidence. - No penalty - AT
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