Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The Tribunal acknowledged the addendum to the agreement as a legitimate clarification of the original intent, despite being executed retrospectively. It emphasized that the addendum did not introduce new terms but clarified the existing understanding regarding the scope of "Third Parties" and royalty payments. - The Tribunal rejected the Revenue's narrower interpretation of "Third Parties" that excluded transactions through Teleperformance USA. It affirmed that services rendered to Teleperformance USA's clients, facilitated by the subsidiary, qualified for royalty payments, aligning with the agreement's broader definition of Third Parties. - The Tribunal concluded that the royalty payments were in accordance with the arm's length principle.
TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The Tribunal acknowledged the addendum to the agreement as a legitimate clarification of the original intent, despite being executed retrospectively. It emphasized that the addendum did not introduce new terms but clarified the existing understanding regarding the scope of "Third Parties" and royalty payments. - The Tribunal rejected the Revenue's narrower interpretation of "Third Parties" that excluded transactions through Teleperformance USA. It affirmed that services rendered to Teleperformance USA's clients, facilitated by the subsidiary, qualified for royalty payments, aligning with the agreement's broader definition of Third Parties. - The Tribunal concluded that the royalty payments were in accordance with the arm's length principle.
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