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...
Refund claim of service tax - Benefit of exemption with retrospective effect - lease premium - time limitation - Request for refund made to wrong forum (service provider / PIPDIC ) initially and not to be service tax department - the petitioner has filed the claim before PIPDIC which is altogether a different entity. However, the mere fact that the entity approached was PIPDIC and not an officer of the Department does not, in the light of the reasoning adduced above, persuade me to take a view adverse to the petitioner as I believe that such a conclusion would be hyper-technical. - HC
Refund claim of service tax - Benefit of exemption with retrospective effect - lease premium - time limitation - Request for refund made to wrong forum (service provider / PIPDIC ) initially and not to be service tax department - the petitioner has filed the claim before PIPDIC which is altogether a different entity. However, the mere fact that the entity approached was PIPDIC and not an officer of the Department does not, in the light of the reasoning adduced above, persuade me to take a view adverse to the petitioner as I believe that such a conclusion would be hyper-technical. - HC
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