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 court held that the revenue authorities cannot question the decision of the Development Commissioner regarding bunching of products for domestic tariff area (DTA) sale within the six-digit Harmonized System (HS) code. In light of the judgments in Ginni International Ltd. and Virlon Textile Mills Ltd., the revenue cannot go beyond or behind the Development Commissioner's decision. The court found no provision in Section 3(1) of the Central Excise Act, 1944, or Rule 100(A) of the Central Excise Rules, 1944, that empowers the revenue authorities to challenge the Development Commissioner's decision. Consequently, the court dismissed the appeal.
The court held that the revenue authorities cannot question the decision of the Development Commissioner regarding bunching of products for domestic tariff area (DTA) sale within the six-digit Harmonized System (HS) code. In light of the judgments in Ginni International Ltd. and Virlon Textile Mills Ltd., the revenue cannot go beyond or behind the Development Commissioner's decision. The court found no provision in Section 3(1) of the Central Excise Act, 1944, or Rule 100(A) of the Central Excise Rules, 1944, that empowers the revenue authorities to challenge the Development Commissioner's decision. Consequently, the court dismissed the appeal.
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