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 note addresses classification of computers moved from SEZ to DTA under Heading 9804, holding that 'dutiable goods' in 9804 means goods chargeable under the Customs Act and does not include goods liable only to IGST; laptops, desktops and exempted monitors therefore fail the first requirement. It also rejects treating SEZ unit sales to customers as 'importation for personal use' for 9804. Separately, the SEZ Act/Rules do not authorize customs-style levy, interest, penalty or confiscation as applied; the impugned adjudication was set aside accordingly.
The note addresses classification of computers moved from SEZ to DTA under Heading 9804, holding that 'dutiable goods' in 9804 means goods chargeable under the Customs Act and does not include goods liable only to IGST; laptops, desktops and exempted monitors therefore fail the first requirement. It also rejects treating SEZ unit sales to customers as 'importation for personal use' for 9804. Separately, the SEZ Act/Rules do not authorize customs-style levy, interest, penalty or confiscation as applied; the impugned adjudication was set aside accordingly.
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