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 consolidated show cause notice covering multiple financial years under Section 74 of the CGST Act was held invalid because limitation and determination are linked year-wise to each financial year's annual return, so each period carries its own independent limitation timeline. The Court found that clubbing distinct tax periods in one notice can prejudice year-specific defences and is not justified unless there is a composite, interlinked fraudulent scheme spanning several years forming an indivisible basis for proceedings; no such allegation was made here. The consolidated notices and consequential adjudication orders were quashed, with liberty to issue fresh year-wise notices if otherwise permissible in law.
A consolidated show cause notice covering multiple financial years under Section 74 of the CGST Act was held invalid because limitation and determination are linked year-wise to each financial year's annual return, so each period carries its own independent limitation timeline. The Court found that clubbing distinct tax periods in one notice can prejudice year-specific defences and is not justified unless there is a composite, interlinked fraudulent scheme spanning several years forming an indivisible basis for proceedings; no such allegation was made here. The consolidated notices and consequential adjudication orders were quashed, with liberty to issue fresh year-wise notices if otherwise permissible in law.
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