Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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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