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...
Natural justice was breached where the Commissioner disagreed with an exoneratory inquiry report without communicating adverse reasons or material to the customs broker and without affording an opportunity to reply; the article emphasises that administrative authorities must disclose adverse material and reasons when they intend to reject a favorable inquiry report so the broker can rebut or explain, and that failure to do so vitiates disciplinary action. The impugned revocation of the customs broker licence was set aside and the appeal allowed for this procedural defect.
Natural justice was breached where the Commissioner disagreed with an exoneratory inquiry report without communicating adverse reasons or material to the customs broker and without affording an opportunity to reply; the article emphasises that administrative authorities must disclose adverse material and reasons when they intend to reject a favorable inquiry report so the broker can rebut or explain, and that failure to do so vitiates disciplinary action. The impugned revocation of the customs broker licence was set aside and the appeal allowed for this procedural defect.
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