Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
Advance Ruling application on maintainability - Reversal of input tax credit to extent of tax element in credit note - no agreement between parties on credit notes not treated as financial/commercial credit notes - no agreement to reduce ITC claim - mismatch of ITC claim figures between GSTR-3B and GSTR-2A - impact of incorrect output tax liability reduction based on credit note issued. Questions on ITC reversal based on credit notes and eligibility to claim ITC based on original invoices admissible u/s 97(2)(d) of CGST Act. Questions on ITC rejection due to GSTR-3B and GSTR-2A mismatch and impact of supplier's incorrect output tax liability reduction on applicant's ITC not covered u/s 97(2). Applicant issued notice u/s 61 for discrepancies, advance ruling filed later. Proceedings pending against applicant, application liable to be rejected u/s 98(2) first proviso.
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