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...
The adhoc exemption order did not restrict the use of floodlights solely for World Cup matches; it aimed to uplift the stadium's infrastructure standards. The department erroneously assumed that World Cup matches were non-commercial, while one-day internationals were commercial. The exemption order made no such distinction. The show cause notice lacked factual or legal basis for alleging a violation of condition (ii). Regarding time limitation, the notice did not allege suppression of facts or intention to evade customs duty. The department issued the notice after collecting documents from the appellant, indicating no suppression. With a lapse of over 7 years, the demand was time-barred as the proviso to Section 28(1) was not applicable. The Appellate Tribunal set aside the impugned order and allowed the appeal.
The adhoc exemption order did not restrict the use of floodlights solely for World Cup matches; it aimed to uplift the stadium's infrastructure standards. The department erroneously assumed that World Cup matches were non-commercial, while one-day internationals were commercial. The exemption order made no such distinction. The show cause notice lacked factual or legal basis for alleging a violation of condition (ii). Regarding time limitation, the notice did not allege suppression of facts or intention to evade customs duty. The department issued the notice after collecting documents from the appellant, indicating no suppression. With a lapse of over 7 years, the demand was time-barred as the proviso to Section 28(1) was not applicable. The Appellate Tribunal set aside the impugned order and allowed the appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
