Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The HC dismissed the writ appeals and upheld the learned Single Judge's disposition allowing the writ petitions to the extent of relegating the petitioners to the post show-cause notice stage. The Court declined to adjudicate merits on liability or exemption under service tax, deeming such issues premature and fact-intensive, and found no jurisdictional error warranting interference with the show cause notices. In certain matters the Court set aside impugned orders-in-original and restored proceedings to the stage of post show-cause notice, granting petitioners liberty to file reply and additional reply as appropriate. The appeals are rejected and the administrative adjudicatory process is remitted for fresh consideration.
The HC dismissed the writ appeals and upheld the learned Single Judge's disposition allowing the writ petitions to the extent of relegating the petitioners to the post show-cause notice stage. The Court declined to adjudicate merits on liability or exemption under service tax, deeming such issues premature and fact-intensive, and found no jurisdictional error warranting interference with the show cause notices. In certain matters the Court set aside impugned orders-in-original and restored proceedings to the stage of post show-cause notice, granting petitioners liberty to file reply and additional reply as appropriate. The appeals are rejected and the administrative adjudicatory process is remitted for fresh consideration.
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