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...
Interim release conditions imposed in writ petitions challenging confiscation orders under Section 130 were upheld because detention matters under Section 129 were not comparable. The Court held that once confiscation is ordered under Section 130, title to the goods and conveyance vests in the Government, and the release mechanism under Section 129 no longer applies. Accordingly, interim terms framed for detention proceedings could not be imported into confiscation cases, and the appellants were not entitled to parity with orders passed in other Section 129 matters. The refusal to modify the interim orders was found to be in accordance with law, and both writ appeals were dismissed.
Interim release conditions imposed in writ petitions challenging confiscation orders under Section 130 were upheld because detention matters under Section 129 were not comparable. The Court held that once confiscation is ordered under Section 130, title to the goods and conveyance vests in the Government, and the release mechanism under Section 129 no longer applies. Accordingly, interim terms framed for detention proceedings could not be imported into confiscation cases, and the appellants were not entitled to parity with orders passed in other Section 129 matters. The refusal to modify the interim orders was found to be in accordance with law, and both writ appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.