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 petition and held that the impugned adjudication violated Section 75(7) of the GST Act by confirming a demand exceeding the amount and grounds specified in the show-cause notice. The court quashed the order insofar as it purported to levy tax, interest and penalty beyond the Rs. 2,10,04,200 specified in the notice, and declared the enhanced demand of Rs. 3,04,55,800 unsustainable. The matter was remitted for fresh adjudication, if any, confined strictly to the amount and grounds articulated in the original notice; any fresh demand must comply with the statutory limits prescribed by Section 75(7).
The HC allowed the petition and held that the impugned adjudication violated Section 75(7) of the GST Act by confirming a demand exceeding the amount and grounds specified in the show-cause notice. The court quashed the order insofar as it purported to levy tax, interest and penalty beyond the Rs. 2,10,04,200 specified in the notice, and declared the enhanced demand of Rs. 3,04,55,800 unsustainable. The matter was remitted for fresh adjudication, if any, confined strictly to the amount and grounds articulated in the original notice; any fresh demand must comply with the statutory limits prescribed by Section 75(7).
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