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 petition challenges the inclusion of CGST amount in petitioner's turnover, contrary to CGST Act definition. Lack of proper personal hearing violates natural justice principles. HC holds statutory appeal remedy cannot be avoided despite 10% payment requirement. Appellate Authority can consider filed documents, assess subordinate officers' conduct. Assessing Officer's difficulty in verifying petitioner's claims due to lack of supporting documents. Court notes petitioner's submission of annual return but deems examination of supporting documents falls under Authority's jurisdiction. Petition dismissed, granting liberty to file appeal.
The petition challenges the inclusion of CGST amount in petitioner's turnover, contrary to CGST Act definition. Lack of proper personal hearing violates natural justice principles. HC holds statutory appeal remedy cannot be avoided despite 10% payment requirement. Appellate Authority can consider filed documents, assess subordinate officers' conduct. Assessing Officer's difficulty in verifying petitioner's claims due to lack of supporting documents. Court notes petitioner's submission of annual return but deems examination of supporting documents falls under Authority's jurisdiction. Petition dismissed, granting liberty to file appeal.
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