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...
The High Court addressed the issue of tax deduction at source for work contracts and supplies, and entitlement to Additional Tax Reimbursement u/s 64A of the Sale of Goods Act, 1930. To invoke Section 64A, two pre-conditions must be met: absence of a contrary contract and duty rate change post-contract. The court referenced MAFATLAL case on unjust enrichment. The case involved potential input tax credit benefits post-July 2017. Circular No. 3/2017-GST mandates GST payment at 6% u/s 12 and 13 of the Act of 2017 and CGST. Court upheld the 6% GST liability for invoices post-July 2017. The court couldn't determine Section 64A benefit due to insufficient evidence. Writ petition was disposed of.
The High Court addressed the issue of tax deduction at source for work contracts and supplies, and entitlement to Additional Tax Reimbursement u/s 64A of the Sale of Goods Act, 1930. To invoke Section 64A, two pre-conditions must be met: absence of a contrary contract and duty rate change post-contract. The court referenced MAFATLAL case on unjust enrichment. The case involved potential input tax credit benefits post-July 2017. Circular No. 3/2017-GST mandates GST payment at 6% u/s 12 and 13 of the Act of 2017 and CGST. Court upheld the 6% GST liability for invoices post-July 2017. The court couldn't determine Section 64A benefit due to insufficient evidence. Writ petition was disposed of.
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