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...
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
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