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...
HC quashed the revisional order regarding maintainability u/s 108 of U.P. GST Act, 2017. The court clarified that Section 108(2) language "order has been subject to appeal" means an appeal must have been actually filed, not that appeal must be exhausted before seeking revision. The Revisional Authority's approach was contradictory - discussing merits while questioning maintainability. The order failed either as a merit-based decision (inadequate consideration of facts) or as a maintainability ruling (misinterpreting Section 108). The provision does not require exhaustion of appeal before revision petition. Matter remanded for fresh consideration of revision petition on merits.
HC quashed the revisional order regarding maintainability u/s 108 of U.P. GST Act, 2017. The court clarified that Section 108(2) language "order has been subject to appeal" means an appeal must have been actually filed, not that appeal must be exhausted before seeking revision. The Revisional Authority's approach was contradictory - discussing merits while questioning maintainability. The order failed either as a merit-based decision (inadequate consideration of facts) or as a maintainability ruling (misinterpreting Section 108). The provision does not require exhaustion of appeal before revision petition. Matter remanded for fresh consideration of revision petition on merits.
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