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 allowed refund claim challenging rejection based on non-submission of documents. The court held that proof of payment is not mandatory for export of goods, and only reconciliation statement of Shipping Bill and Export Invoices is required. The RBI circular stipulates payment realization within 9 months, which was satisfied in this case. The order rejecting refund was deemed unsustainable as it was based on grounds beyond CGST Act & Rules, effectively invalidating the original administrative decision and granting relief to the petitioner.
HC allowed refund claim challenging rejection based on non-submission of documents. The court held that proof of payment is not mandatory for export of goods, and only reconciliation statement of Shipping Bill and Export Invoices is required. The RBI circular stipulates payment realization within 9 months, which was satisfied in this case. The order rejecting refund was deemed unsustainable as it was based on grounds beyond CGST Act & Rules, effectively invalidating the original administrative decision and granting relief to the petitioner.
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