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The HC held the petition maintainable and allowed relief, ruling that Rule 96(10) of the CGST Rules, having been repealed by notification dated 8 October 2024 and lacking a savings clause, caused all pending proceedings based on that Rule to lapse insofar as they do not pertain to past and closed transactions. Although alternate statutory remedies ordinarily preclude writ jurisdiction, the court found the present grievance substantially covered by an earlier HC decision and concluded it would be futile to require exhaustion of alternate remedies. The court therefore granted relief, including quashing of proceedings initiated under the repealed provision, and allowed the petition.
The HC held the petition maintainable and allowed relief, ruling that Rule 96(10) of the CGST Rules, having been repealed by notification dated 8 October 2024 and lacking a savings clause, caused all pending proceedings based on that Rule to lapse insofar as they do not pertain to past and closed transactions. Although alternate statutory remedies ordinarily preclude writ jurisdiction, the court found the present grievance substantially covered by an earlier HC decision and concluded it would be futile to require exhaustion of alternate remedies. The court therefore granted relief, including quashing of proceedings initiated under the repealed provision, and allowed the petition.
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