Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
GST liability on works executed under pre-GST contracts remains governed exclusively by the applicable GST enactments and cannot be altered by contractual terms or an employer's failure to reimburse differential tax. A contractor's claim for incremental GST reimbursement is confined to the contractual relationship with the concerned employer and does not bind tax authorities. Revised returns, waiver of interest or penalties, and relaxation of statutory limitation cannot be granted through directions arising from a contractual reimbursement dispute, as these matters remain subject to the GST statutory framework. Directions affecting tax authorities or the State beyond that framework were treated as unsustainable.
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