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...
Under the GST job-work scheme, the principal must maintain the accounts and records required by Section 143 and Rule 45, and failure to show return of goods within the prescribed period attracts the statutory deeming consequence. On that basis, invocation of Section 74 and the extended limitation was upheld, and the technical challenge to the notices and orders for want of separate recitals of every ingredient was rejected. The assessee's plea of revenue neutrality was not decided in writ proceedings because it depended on disputed facts about tax already suffered on the inputs; that issue was remitted for fresh reply and merits-based reconsideration.
Under the GST job-work scheme, the principal must maintain the accounts and records required by Section 143 and Rule 45, and failure to show return of goods within the prescribed period attracts the statutory deeming consequence. On that basis, invocation of Section 74 and the extended limitation was upheld, and the technical challenge to the notices and orders for want of separate recitals of every ingredient was rejected. The assessee's plea of revenue neutrality was not decided in writ proceedings because it depended on disputed facts about tax already suffered on the inputs; that issue was remitted for fresh reply and merits-based reconsideration.
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