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...
Denial of benefit of Notification No. 12/03-ST - it can be seen that as against the abatement of 67% available under Notification No. 15/04-ST and 01/06-ST - the appellant have taken the abatement ranging from 30% to 48%. Thus, despite the availability of abatement as per the above notification, the appellant have paid the service tax on much higher value, for this reason also the demand is absolutely unsustainable. - AT
Denial of benefit of Notification No. 12/03-ST - it can be seen that as against the abatement of 67% available under Notification No. 15/04-ST and 01/06-ST - the appellant have taken the abatement ranging from 30% to 48%. Thus, despite the availability of abatement as per the above notification, the appellant have paid the service tax on much higher value, for this reason also the demand is absolutely unsustainable. - AT
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