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...
Imports made under an Advance Authorisation Scheme were treated as not liable to CVD for the intervening period, because the Tribunal followed its earlier ruling in M/s. Vishal Metal Industries and applied the later exemption notification retrospectively to that period where export obligation had been fulfilled. On that basis, the CVD demand was unsustainable, and the consequential confiscation, interest and penalties also could not survive. The impugned order was set aside in full and the appeals were allowed.
Imports made under an Advance Authorisation Scheme were treated as not liable to CVD for the intervening period, because the Tribunal followed its earlier ruling in M/s. Vishal Metal Industries and applied the later exemption notification retrospectively to that period where export obligation had been fulfilled. On that basis, the CVD demand was unsustainable, and the consequential confiscation, interest and penalties also could not survive. The impugned order was set aside in full and the appeals were allowed.
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