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...
Section 11(6) of the VAT Act cannot be read as authorising a State to curtail reimbursement of tax on declared goods in a manner inconsistent with Article 286(3) of the Constitution and section 15(b) of the CST Act. The Gujarat HC, following Hides and Skin Owners Seva Mandal, treated Kadwani Forge Ltd. as sub silentio on transactions where goods purchased and sold were both declared goods. The notification was therefore upheld in general, but held inapplicable to declared goods such as coke bought within the State and resold in inter-State trade and commerce, requiring full input tax credit and rendering the show cause notice unsustainable.
Section 11(6) of the VAT Act cannot be read as authorising a State to curtail reimbursement of tax on declared goods in a manner inconsistent with Article 286(3) of the Constitution and section 15(b) of the CST Act. The Gujarat HC, following Hides and Skin Owners Seva Mandal, treated Kadwani Forge Ltd. as sub silentio on transactions where goods purchased and sold were both declared goods. The notification was therefore upheld in general, but held inapplicable to declared goods such as coke bought within the State and resold in inter-State trade and commerce, requiring full input tax credit and rendering the show cause notice unsustainable.
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