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 Sabka Vishwas (Legacy Dispute Resolution) Scheme, a declaration lapsed when the declarant failed to pay the amount in Form SVLDRS-3 within the prescribed 30 days; the Tribunal applied the plain meaning of the Scheme and held that no equitable or purposive relief could override the statutory time limit. The belated payment made after the extended last date did not preserve the amnesty benefit, so the service tax demand and interest were sustained. Penalty was, however, set aside because the delay occurred during the COVID period and there was no finding of mala fide intent.
Under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, a declaration lapsed when the declarant failed to pay the amount in Form SVLDRS-3 within the prescribed 30 days; the Tribunal applied the plain meaning of the Scheme and held that no equitable or purposive relief could override the statutory time limit. The belated payment made after the extended last date did not preserve the amnesty benefit, so the service tax demand and interest were sustained. Penalty was, however, set aside because the delay occurred during the COVID period and there was no finding of mala fide intent.
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