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 set aside the Order-in-Original and Summary Order under Section 73 of GST Act due to violation of principles of natural justice. The adjudicating authority failed to consider the petitioner's reply to show-cause notice and supporting documents filed on 20.12.2024 before passing the order on 20.02.2025. The matter was remitted for fresh adjudication, emphasizing that administrative authorities must comprehensively examine all submitted evidence before rendering a decision. The court underscored the fundamental requirement of procedural fairness in administrative proceedings, mandating a thorough review of all representations and documentary evidence.
HC set aside the Order-in-Original and Summary Order under Section 73 of GST Act due to violation of principles of natural justice. The adjudicating authority failed to consider the petitioner's reply to show-cause notice and supporting documents filed on 20.12.2024 before passing the order on 20.02.2025. The matter was remitted for fresh adjudication, emphasizing that administrative authorities must comprehensively examine all submitted evidence before rendering a decision. The court underscored the fundamental requirement of procedural fairness in administrative proceedings, mandating a thorough review of all representations and documentary evidence.
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