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 HC addressed the jurisdiction of DRI officials to issue show cause notices under Section 28 of the Customs Act, 1962. Following the Supreme Court's decision in Canon-II, the Court determined that the challenged SCN dated November 17, 2017, issued by DRI Lucknow Zonal Unit, falls under paragraph 168(vi)(a) of Canon-II. Consequently, the proceedings initiated by the SCN will continue before the appropriate adjudicating authority according to law. Given the lengthy pendency of the petition, the petitioner was granted 60 days to respond to the SCN and assured a personal hearing before adjudication. The petition was disposed of accordingly.
The HC addressed the jurisdiction of DRI officials to issue show cause notices under Section 28 of the Customs Act, 1962. Following the Supreme Court's decision in Canon-II, the Court determined that the challenged SCN dated November 17, 2017, issued by DRI Lucknow Zonal Unit, falls under paragraph 168(vi)(a) of Canon-II. Consequently, the proceedings initiated by the SCN will continue before the appropriate adjudicating authority according to law. Given the lengthy pendency of the petition, the petitioner was granted 60 days to respond to the SCN and assured a personal hearing before adjudication. The petition was disposed of accordingly.
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