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...
Petition dismissed for want of locus to challenge detention and confiscation proceedings where High Court found insufficient nexus between petitioner and intercepted consignment; E-way bill showed different dispatch and consignee locations, registration and documentation discrepancies, and neither supplier nor recipient sought release, leading the Court to conclude lack of standing. Court also refused to quash the show cause notice under Section 130, treating interference as premature in view of precedent and noting indicia of tax evasion and deceptive documentation on the record.
Petition dismissed for want of locus to challenge detention and confiscation proceedings where High Court found insufficient nexus between petitioner and intercepted consignment; E-way bill showed different dispatch and consignee locations, registration and documentation discrepancies, and neither supplier nor recipient sought release, leading the Court to conclude lack of standing. Court also refused to quash the show cause notice under Section 130, treating interference as premature in view of precedent and noting indicia of tax evasion and deceptive documentation on the record.
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