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...
After remand, the Assessing Officer had to adjudicate the original GST show cause notice for the same financial year by granting personal hearing and considering the reply; issuing a second notice instead was contrary to the earlier HC directions and amounted to overreaching the court order. The HC did not examine the merits of Section 74 and set aside the adjudication order solely on this procedural ground, remanding the matter for fresh decision on the basis of the first notice after personal hearing and due consideration of the reply.
After remand, the Assessing Officer had to adjudicate the original GST show cause notice for the same financial year by granting personal hearing and considering the reply; issuing a second notice instead was contrary to the earlier HC directions and amounted to overreaching the court order. The HC did not examine the merits of Section 74 and set aside the adjudication order solely on this procedural ground, remanding the matter for fresh decision on the basis of the first notice after personal hearing and due consideration of the reply.
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