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...
Failure to place the Letter of Undertaking and SEZ Certificate before the adjudicating authority led the HC to set aside the assessment orders and remit the matter for fresh adjudication. The Court noted that the petitioner's zero-rated supply and SEZ-based claim could not be finally examined without those documents, and it granted one further opportunity to file an additional reply and produce them. The Court expressly declined to decide the merits, including the claim under the IGST framework, leaving all substantive issues open for reconsideration.
Failure to place the Letter of Undertaking and SEZ Certificate before the adjudicating authority led the HC to set aside the assessment orders and remit the matter for fresh adjudication. The Court noted that the petitioner's zero-rated supply and SEZ-based claim could not be finally examined without those documents, and it granted one further opportunity to file an additional reply and produce them. The Court expressly declined to decide the merits, including the claim under the IGST framework, leaving all substantive issues open for reconsideration.
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