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...
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The circular prescribes the workflow for departmental appeals, cross-objections and replies before the GST Appellate Tribunal and its Principal Bench. It requires zone-wise scrutiny of adverse appellate orders by a committee, opinion by the relevant Joint Commissioner or Additional Commissioner within fixed timelines, and Commissioner authorization before filing. Draft appeal memoranda must be prepared in English at the originating office level, vetted by the State Representative, and filed online with defect rectification ensured. It also sets a mechanism for dropping cases, applies the same procedure where taxpayers file appeals, and assigns representative authority subject to monetary limits, while preserving filing where substantial questions of law arise and superseding earlier instructions.
The circular prescribes the workflow for departmental appeals, cross-objections and replies before the GST Appellate Tribunal and its Principal Bench. It requires zone-wise scrutiny of adverse appellate orders by a committee, opinion by the relevant Joint Commissioner or Additional Commissioner within fixed timelines, and Commissioner authorization before filing. Draft appeal memoranda must be prepared in English at the originating office level, vetted by the State Representative, and filed online with defect rectification ensured. It also sets a mechanism for dropping cases, applies the same procedure where taxpayers file appeals, and assigns representative authority subject to monetary limits, while preserving filing where substantial questions of law arise and superseding earlier instructions.
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