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...
Refund of SAD - The case involved refund claims filed by the appellant under Customs Notification No.102/2007-Cus. for Special Additional Duty of Customs paid during the import of goods. While a part of the refund claim was sanctioned, the original authority rejected the claim for two Bills of Entry, citing discrepancies between invoice dates and dates of Bill of Entry. The appellant contended that the rejection was based on unfounded assumptions by the department, clarifying that goods were intended for delivery at Sivakasi and were transported directly from Chennai to Sivakasi. The Tribunal found the rejection erroneous, emphasizing that an importer can arrange for direct delivery to the customer from the port.
Refund of SAD - The case involved refund claims filed by the appellant under Customs Notification No.102/2007-Cus. for Special Additional Duty of Customs paid during the import of goods. While a part of the refund claim was sanctioned, the original authority rejected the claim for two Bills of Entry, citing discrepancies between invoice dates and dates of Bill of Entry. The appellant contended that the rejection was based on unfounded assumptions by the department, clarifying that goods were intended for delivery at Sivakasi and were transported directly from Chennai to Sivakasi. The Tribunal found the rejection erroneous, emphasizing that an importer can arrange for direct delivery to the customer from the port.
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