Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Amendment by substitution to condition (6) of an exemption notification inserting the word "premises" was held capable of retrospective operation and must receive a beneficial construction where it remedies an obvious omission, making the importer eligible; accordingly, departmental reliance on the original text when issuing a show cause notice that post dated the substituted condition was legally erroneous. The show cause notice and consequent orders were quashed and the appellant was directed to receive benefits under the notification as amended, with consequential payment ordered.
Amendment by substitution to condition (6) of an exemption notification inserting the word "premises" was held capable of retrospective operation and must receive a beneficial construction where it remedies an obvious omission, making the importer eligible; accordingly, departmental reliance on the original text when issuing a show cause notice that post dated the substituted condition was legally erroneous. The show cause notice and consequent orders were quashed and the appellant was directed to receive benefits under the notification as amended, with consequential payment ordered.
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