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...
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
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