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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Refund claim - Period of limitation - Double Taxation - The respondent had also paid tax on the same invoices. - The petitioner sought direction for the refund of Input Tax Credit (ITC) paid on invoices for a specific period, alleging coercion due to the respondent's delayed filing of returns. The respondent argued that the petitioner's claim lacked merit due to the absence of a proper refund application. The court disposed of the petition by permitting the petitioner to file a refund application within one week, considering the exclusion of certain periods for limitation purposes.
Refund claim - Period of limitation - Double Taxation - The respondent had also paid tax on the same invoices. - The petitioner sought direction for the refund of Input Tax Credit (ITC) paid on invoices for a specific period, alleging coercion due to the respondent's delayed filing of returns. The respondent argued that the petitioner's claim lacked merit due to the absence of a proper refund application. The court disposed of the petition by permitting the petitioner to file a refund application within one week, considering the exclusion of certain periods for limitation purposes.
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