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...
Mere inquiry communications, summons or intimation do not amount to initiation of adjudicatory proceedings; a show cause notice does. Applying that principle, the first show cause notice on the same GST subject matter was treated as governing the proceedings, and the authority issuing it had to continue and complete the matter. Other authorities dealing with the same issue were restrained from proceeding independently and were required to forward their material to the adjudicating authority, with prior intimation to the petitioner so it could respond effectively.
Mere inquiry communications, summons or intimation do not amount to initiation of adjudicatory proceedings; a show cause notice does. Applying that principle, the first show cause notice on the same GST subject matter was treated as governing the proceedings, and the authority issuing it had to continue and complete the matter. Other authorities dealing with the same issue were restrained from proceeding independently and were required to forward their material to the adjudicating authority, with prior intimation to the petitioner so it could respond effectively.
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