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 rejected the rectification application, finding no procedural fault by the Respondent-Department. The Court held that the petitioner failed to provide substantive reasoning in the application. While granting time until 10th July, 2025 to file an appeal under Section 107 of CGST Act, the Court left open the issue of notification validity, subject to pending Supreme Court and High Court decisions in related matters. The petitioner was advised to pursue remedies through the appellate authority, with the final determination contingent on ongoing judicial proceedings.
HC rejected the rectification application, finding no procedural fault by the Respondent-Department. The Court held that the petitioner failed to provide substantive reasoning in the application. While granting time until 10th July, 2025 to file an appeal under Section 107 of CGST Act, the Court left open the issue of notification validity, subject to pending Supreme Court and High Court decisions in related matters. The petitioner was advised to pursue remedies through the appellate authority, with the final determination contingent on ongoing judicial proceedings.
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