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...
Reusable metal containers owned by an overseas supplier and imported with raw material were not treated as separately dutiable goods under the Customs Act, 1962; applying the Supreme Court principle in Chairman, Board of Trustees, Cochin Port Trust v. Arebee Star Maritime Agencies, the Tribunal held that duty could not be demanded again on the containers. Under section 14 read with Rule 10(1) of the Customs Valuation Rules, 2007, only packing cost actually incurred or payable by the importer could be included, and the rental value of the packing material was already reflected in the CIF value of the imported synthetic rubber. The reassessment, including interest and penalties, was set aside.
Reusable metal containers owned by an overseas supplier and imported with raw material were not treated as separately dutiable goods under the Customs Act, 1962; applying the Supreme Court principle in Chairman, Board of Trustees, Cochin Port Trust v. Arebee Star Maritime Agencies, the Tribunal held that duty could not be demanded again on the containers. Under section 14 read with Rule 10(1) of the Customs Valuation Rules, 2007, only packing cost actually incurred or payable by the importer could be included, and the rental value of the packing material was already reflected in the CIF value of the imported synthetic rubber. The reassessment, including interest and penalties, was set aside.
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