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...
Denial of the right to cross-examine witnesses under the Customs Brokers Licensing Regulations vitiated disciplinary proceedings because Regulation 17(4) creates a mandatory procedural protection; the inquiry relied on oral statements that the respondent was not permitted to test, and that breach rendered the revocation order unsustainable. The Tribunal correctly set aside the revocation for non compliance with Regulation 17(4) and breach of natural justice. Any findings about prescribed timelines were rendered immaterial where procedural fairness under Regulation 17(4) was violated, and the High Court found no substantial question of law requiring interference.
Denial of the right to cross-examine witnesses under the Customs Brokers Licensing Regulations vitiated disciplinary proceedings because Regulation 17(4) creates a mandatory procedural protection; the inquiry relied on oral statements that the respondent was not permitted to test, and that breach rendered the revocation order unsustainable. The Tribunal correctly set aside the revocation for non compliance with Regulation 17(4) and breach of natural justice. Any findings about prescribed timelines were rendered immaterial where procedural fairness under Regulation 17(4) was violated, and the High Court found no substantial question of law requiring interference.
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