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...
Petitioner sought to quash the show-cause notice (SCN) demanding Integrated Goods and Services Tax (IGST) along with interest and penalty on salaries paid to expatriates. The issue pertained to whether the supply of manpower and recruitment services from overseas group entities to the petitioner attracted IGST. The High Court did not delve into the merits but relegated the matter to the stage of reply to the SCN. The authorities were directed to consider the applicability of Circular No. 210/4/2024-GST dated 26.06.2024 while adjudicating the reply. The petitioner was granted three weeks to file the reply from the receipt of the order's certified copy.
Petitioner sought to quash the show-cause notice (SCN) demanding Integrated Goods and Services Tax (IGST) along with interest and penalty on salaries paid to expatriates. The issue pertained to whether the supply of manpower and recruitment services from overseas group entities to the petitioner attracted IGST. The High Court did not delve into the merits but relegated the matter to the stage of reply to the SCN. The authorities were directed to consider the applicability of Circular No. 210/4/2024-GST dated 26.06.2024 while adjudicating the reply. The petitioner was granted three weeks to file the reply from the receipt of the order's certified copy.
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