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...
Impugned order quashed and matter remanded for fresh consideration. HC found non-application of mind, non-consideration of Petitioner's reply to show cause notice, and lack of reasoning in passing order u/s 168-A of CGST Act read with DGST Act for failure to declare correct tax liability in GSTR-09. Relying on coordinate bench judgments in Indian Highways and Chetak Logistic, HC held impugned order untenable for being passed in cavalier manner without deciding on merits, thereby violating principles of natural justice.
Impugned order quashed and matter remanded for fresh consideration. HC found non-application of mind, non-consideration of Petitioner's reply to show cause notice, and lack of reasoning in passing order u/s 168-A of CGST Act read with DGST Act for failure to declare correct tax liability in GSTR-09. Relying on coordinate bench judgments in Indian Highways and Chetak Logistic, HC held impugned order untenable for being passed in cavalier manner without deciding on merits, thereby violating principles of natural justice.
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