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...
Adjustment of integrated tax paid under the wrong head against intra-State tax liability requires Section 77(2) to be read with Rule 92. Rule 92 contemplates setting off a refund entitlement against an outstanding demand through the prescribed adjustment order. The text states that an undisputed erroneous IGST payment for an intra-State supply should not create tax, interest or penalty liability without considering this adjustment mechanism. It describes the quashing of the adjudication, appellate and demand orders and remand for fresh consideration of adjustment under Section 77(2) and Rule 92.
Adjustment of integrated tax paid under the wrong head against intra-State tax liability requires Section 77(2) to be read with Rule 92. Rule 92 contemplates setting off a refund entitlement against an outstanding demand through the prescribed adjustment order. The text states that an undisputed erroneous IGST payment for an intra-State supply should not create tax, interest or penalty liability without considering this adjustment mechanism. It describes the quashing of the adjudication, appellate and demand orders and remand for fresh consideration of adjustment under Section 77(2) and Rule 92.
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