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 petitioner's challenge to proceedings under Section 74 of the UPGST Act succeeds and the impugned orders are quashed. The court found that on the date of the transaction the supplier possessed valid registration and the supply was effected through a genuine billing channel characterized as a "Bill To Ship To" transaction with an e-way bill and vehicle identification; subsequent cancellation of the supplier's registration cannot retrospectively render the transaction bogus. In absence of any contradictory or adverse material on record to rebut the petitioner's factual pleas, no legal basis existed to sustain reversal of the input tax credit or other punitive measures. Petition allowed.
HC held that the petitioner's challenge to proceedings under Section 74 of the UPGST Act succeeds and the impugned orders are quashed. The court found that on the date of the transaction the supplier possessed valid registration and the supply was effected through a genuine billing channel characterized as a "Bill To Ship To" transaction with an e-way bill and vehicle identification; subsequent cancellation of the supplier's registration cannot retrospectively render the transaction bogus. In absence of any contradictory or adverse material on record to rebut the petitioner's factual pleas, no legal basis existed to sustain reversal of the input tax credit or other punitive measures. Petition allowed.
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