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 HC quashed the order passed u/s 73 of the CGST Act by the Assistant Commissioner due to lack of reasoning, non-application of mind, and violation of principles of natural justice. The Assistant Commissioner adopted an identical template, merely stating that the reply filed was "not comprehensible, conceivable, not perspicuous and is ambiguous" without any substantive reasoning, despite previous cautions against using such a template. The HC held that this exhibited an abject non-application of mind and failure to make amends despite earlier directions.
The HC quashed the order passed u/s 73 of the CGST Act by the Assistant Commissioner due to lack of reasoning, non-application of mind, and violation of principles of natural justice. The Assistant Commissioner adopted an identical template, merely stating that the reply filed was "not comprehensible, conceivable, not perspicuous and is ambiguous" without any substantive reasoning, despite previous cautions against using such a template. The HC held that this exhibited an abject non-application of mind and failure to make amends despite earlier directions.
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