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 ruled in favor of petitioner regarding detained goods due to expired e-way bill during intra-state stock transfer. While authorities detained goods citing e-way bill expiration, petitioner demonstrated goods were part of legitimate stock transfer between units, not a sale transaction. Driver's delay was documented through contemporaneous letter explaining personal emergency. Court found no evidence of tax evasion intent, following SC precedent in Satyam Shivam Papers. Detention, seizure, and penalty were deemed unjustified as basic compliance requirements for intra-state transfer were met despite procedural lapse. HC emphasized substance over form, noting absence of fraudulent intent or revenue loss. Petition allowed with costs.
HC ruled in favor of petitioner regarding detained goods due to expired e-way bill during intra-state stock transfer. While authorities detained goods citing e-way bill expiration, petitioner demonstrated goods were part of legitimate stock transfer between units, not a sale transaction. Driver's delay was documented through contemporaneous letter explaining personal emergency. Court found no evidence of tax evasion intent, following SC precedent in Satyam Shivam Papers. Detention, seizure, and penalty were deemed unjustified as basic compliance requirements for intra-state transfer were met despite procedural lapse. HC emphasized substance over form, noting absence of fraudulent intent or revenue loss. Petition allowed with costs.
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