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...
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
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