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...
A Customs Broker was not shown to have breached regulations 10(d), 10(e) or 10(n) of the 2018 Regulations. Regulation 10(d) only required advice to the client to comply with the Act and allied laws, and the authorization letter recorded that such advice had been given, so no further particulars were necessary. Regulation 10(e) was not violated because the exporter held a valid GST registration on the relevant export date, making the earlier cancellation immaterial. Regulation 10(n) also failed on the same basis, and the Tribunal noted that the Joint Commissioner had found no breach. The revocation of the licence and forfeiture of security were set aside, and restoration of the licence was directed.
A Customs Broker was not shown to have breached regulations 10(d), 10(e) or 10(n) of the 2018 Regulations. Regulation 10(d) only required advice to the client to comply with the Act and allied laws, and the authorization letter recorded that such advice had been given, so no further particulars were necessary. Regulation 10(e) was not violated because the exporter held a valid GST registration on the relevant export date, making the earlier cancellation immaterial. Regulation 10(n) also failed on the same basis, and the Tribunal noted that the Joint Commissioner had found no breach. The revocation of the licence and forfeiture of security were set aside, and restoration of the licence was directed.
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