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...
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HC condoned a 35-day delay in filing GST appeal, emphasizing that procedural delays should not override substantive justice. The petitioner had demonstrated compliance by depositing 10% of tax liability and making additional payments toward disputed amount. Court found strict application of GST Act's limitation provisions unwarranted given circumstances. Matter remanded to second respondent for fresh consideration on merits, directing full examination of facts and circumstances. Decision underscores judicial preference for substantive resolution over procedural dismissal in tax matters where appellant shows good faith compliance efforts.
HC condoned a 35-day delay in filing GST appeal, emphasizing that procedural delays should not override substantive justice. The petitioner had demonstrated compliance by depositing 10% of tax liability and making additional payments toward disputed amount. Court found strict application of GST Act's limitation provisions unwarranted given circumstances. Matter remanded to second respondent for fresh consideration on merits, directing full examination of facts and circumstances. Decision underscores judicial preference for substantive resolution over procedural dismissal in tax matters where appellant shows good faith compliance efforts.
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