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...
Tribunal held that where original goods were exported, a replacement consignment was subsequently exported and the defective originals were re-imported, and a chartered accountant certified no extra charge and that export benefits were claimed only once, the re-importation falls under the provision for replacement consignments (Sr. No. 5) rather than the general re-importation entry (Sr. No. 1). Consequently the appellant may retain the export benefits taken on the original export, is not liable to reverse them with interest, and the amount surrendered to clear the re-imported goods must be refunded on application.
Tribunal held that where original goods were exported, a replacement consignment was subsequently exported and the defective originals were re-imported, and a chartered accountant certified no extra charge and that export benefits were claimed only once, the re-importation falls under the provision for replacement consignments (Sr. No. 5) rather than the general re-importation entry (Sr. No. 1). Consequently the appellant may retain the export benefits taken on the original export, is not liable to reverse them with interest, and the amount surrendered to clear the re-imported goods must be refunded on application.
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