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 held that while the State's tax exemption policy amendment under GST regime was valid, the arbitrary non-consideration of petitioners' extension applications compared to other similarly situated industries violated Article 14. The court directed respondent authorities to reconsider petitioners' claims within 60 days using identical evaluation criteria applied to other units. The doctrine of promissory estoppel was not applicable given public policy considerations and legal regime changes. Petitioners' claims for full tax exemption were rejected, but they were granted an opportunity for fair administrative review of their extension applications.
HC held that while the State's tax exemption policy amendment under GST regime was valid, the arbitrary non-consideration of petitioners' extension applications compared to other similarly situated industries violated Article 14. The court directed respondent authorities to reconsider petitioners' claims within 60 days using identical evaluation criteria applied to other units. The doctrine of promissory estoppel was not applicable given public policy considerations and legal regime changes. Petitioners' claims for full tax exemption were rejected, but they were granted an opportunity for fair administrative review of their extension applications.
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