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 dismissed the petition challenging tax order, finding the petitioner failed to exercise due diligence in responding to show cause notices and personal hearing opportunities. Despite receiving multiple notices dated 22nd July, 2022 and 3rd August, 2024, the petitioner neither filed replies nor attended hearings. The court held that the administrative authority provided fair opportunity for hearing, and the petitioner's lack of proactive engagement precluded claims of procedural impropriety. The order under Section 107 of CGST Act, 2017 was upheld, and the petition was disposed of without substantive intervention.
HC dismissed the petition challenging tax order, finding the petitioner failed to exercise due diligence in responding to show cause notices and personal hearing opportunities. Despite receiving multiple notices dated 22nd July, 2022 and 3rd August, 2024, the petitioner neither filed replies nor attended hearings. The court held that the administrative authority provided fair opportunity for hearing, and the petitioner's lack of proactive engagement precluded claims of procedural impropriety. The order under Section 107 of CGST Act, 2017 was upheld, and the petition was disposed of without substantive intervention.
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