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 finds SCN under Finance Act, 1994 and CGST Act, 2017 procedurally defective. The 2nd respondent failed to provide adequate hearing and did not properly consider the petitioner's submissions, violating principles of natural justice. Consequently, the impugned order dated 21.03.2022 was set aside and the matter remanded for fresh consideration, ensuring the petitioner receives fair opportunity to present arguments. The court's intervention rectifies procedural irregularities without adjudicating the substantive merits of the original dispute, thereby upholding fundamental principles of administrative justice.
HC finds SCN under Finance Act, 1994 and CGST Act, 2017 procedurally defective. The 2nd respondent failed to provide adequate hearing and did not properly consider the petitioner's submissions, violating principles of natural justice. Consequently, the impugned order dated 21.03.2022 was set aside and the matter remanded for fresh consideration, ensuring the petitioner receives fair opportunity to present arguments. The court's intervention rectifies procedural irregularities without adjudicating the substantive merits of the original dispute, thereby upholding fundamental principles of administrative justice.
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