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...
GST applied to works completed after commencement of the GST regime. The notes state that contract bills deducted tendered KVAT and Service Tax components from the contract amount before adding GST, so simultaneous levy of KVAT and GST and resulting double taxation were not established. The tax adjustment explanation was described as consistent with the statutory scheme. They further distinguish disputes over bill calculations as factual matters for consideration by the appropriate forum rather than writ proceedings, while preserving the contractor's ability to seek resolution before jurisdictional authorities.
GST applied to works completed after commencement of the GST regime. The notes state that contract bills deducted tendered KVAT and Service Tax components from the contract amount before adding GST, so simultaneous levy of KVAT and GST and resulting double taxation were not established. The tax adjustment explanation was described as consistent with the statutory scheme. They further distinguish disputes over bill calculations as factual matters for consideration by the appropriate forum rather than writ proceedings, while preserving the contractor's ability to seek resolution before jurisdictional authorities.
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