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...
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Demand u/s 74 - violation of principles of natural justice - The High court noted that Section 75(4) of the CGST Act mandates that an opportunity for hearing must be granted either when a specific request is received in writing from a person chargeable with tax or when any adverse decision is contemplated against such a person. The court found that even if the petitioners did not specifically request a personal hearing, they were entitled to one since an adverse decision was contemplated against them.
Demand u/s 74 - violation of principles of natural justice - The High court noted that Section 75(4) of the CGST Act mandates that an opportunity for hearing must be granted either when a specific request is received in writing from a person chargeable with tax or when any adverse decision is contemplated against such a person. The court found that even if the petitioners did not specifically request a personal hearing, they were entitled to one since an adverse decision was contemplated against them.
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