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...
Where the proper officer verifies a certificate of origin under the preferential tariff scheme, provisional release of imported goods must preserve revenue protection. The High Court stressed judicial restraint in revenue matters and required strict compliance with the Act, Rules and Circular governing such verification. Because verification had been delayed, the Court directed completion within three weeks. If the declared country of origin is confirmed, release is to follow in accordance with law; if it is found incorrect or false, provisional release must be supported by a 100% bank guarantee as prescribed in the circular.
Where the proper officer verifies a certificate of origin under the preferential tariff scheme, provisional release of imported goods must preserve revenue protection. The High Court stressed judicial restraint in revenue matters and required strict compliance with the Act, Rules and Circular governing such verification. Because verification had been delayed, the Court directed completion within three weeks. If the declared country of origin is confirmed, release is to follow in accordance with law; if it is found incorrect or false, provisional release must be supported by a 100% bank guarantee as prescribed in the circular.
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