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 the tax authority improperly issued a show-cause notice demanding reversal of Input Tax Credit (ITC) without considering the petitioner's prior voluntary reversal. The non-speaking order violated principles of natural justice by seeking double recovery of tax. The court remanded the matter, directing the authority to issue a fresh order focusing on potential interest or penalty for late ITC reversal, and provide the petitioner an opportunity to be heard. The order emphasizes procedural fairness and prevents excessive tax recovery, mandating a comprehensive review of actual tax compliance before imposing additional financial burden.
HC held that the tax authority improperly issued a show-cause notice demanding reversal of Input Tax Credit (ITC) without considering the petitioner's prior voluntary reversal. The non-speaking order violated principles of natural justice by seeking double recovery of tax. The court remanded the matter, directing the authority to issue a fresh order focusing on potential interest or penalty for late ITC reversal, and provide the petitioner an opportunity to be heard. The order emphasizes procedural fairness and prevents excessive tax recovery, mandating a comprehensive review of actual tax compliance before imposing additional financial burden.
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