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...
Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
Shipping bill amendments were allowed under Section 149 to correct the reward column from "No" to "Yes" for MEIS claims, as the wrong entry was treated as a curable procedural lapse and not a bar to substantive export incentive. The Tribunal held that delay in seeking amendment must be assessed on the facts of each case, and the notification-based time limit could be extended where the competent customs authority was satisfied with the explanation. The preliminary forum objection was rejected because the matter had long remained before a Single Member without objection from Revenue. Consequential relief was granted.
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