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...
The penalty-only pre-deposit proviso to section 112(8) of the CGST Act applies prospectively from 1 October 2025. The text states that, because the impugned appellate order predated that effective date and the amendment did not expressly or necessarily imply retrospective operation, the pre-deposit condition could not attach to a substantive right of appeal arising from proceedings instituted earlier. Accordingly, no pre-deposit was required for admission of the penalty-only GST appeal, without affecting the merits or any direction at final hearing.
The penalty-only pre-deposit proviso to section 112(8) of the CGST Act applies prospectively from 1 October 2025. The text states that, because the impugned appellate order predated that effective date and the amendment did not expressly or necessarily imply retrospective operation, the pre-deposit condition could not attach to a substantive right of appeal arising from proceedings instituted earlier. Accordingly, no pre-deposit was required for admission of the penalty-only GST appeal, without affecting the merits or any direction at final hearing.
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