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...
Uploading the show-cause notice only under the GST portal's 'Additional notice and orders' tab prevented a reply and violated natural justice. The HC also identified a material mismatch between the financial year covered by the appellate order and those in recovery and garnishee proceedings. It set aside the time-bar dismissal, quashed the appellate order, and required the GST appeal to be entertained and decided on merits, with all merits left open. The delay explanation was to be considered sufficient by the appellate authority, and no further pre-deposit was required. The recovery-related discrepancy warranted a further opportunity to the taxpayer.
Uploading the show-cause notice only under the GST portal's 'Additional notice and orders' tab prevented a reply and violated natural justice. The HC also identified a material mismatch between the financial year covered by the appellate order and those in recovery and garnishee proceedings. It set aside the time-bar dismissal, quashed the appellate order, and required the GST appeal to be entertained and decided on merits, with all merits left open. The delay explanation was to be considered sufficient by the appellate authority, and no further pre-deposit was required. The recovery-related discrepancy warranted a further opportunity to the taxpayer.
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