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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The HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
The HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
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