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...
The HC allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
The HC allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
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