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 dismissed the writ petition challenging three Orders-in-Original concerning demands for allegedly fraudulent availment of ITC, holding that factual determinations on fraudulent ITC cannot be adjudicated in writ jurisdiction and noting precedent from higher courts. The Court found non-entertainment of the writ appropriate and declined to interfere on merits for lack of natural justice issues warranting writ relief. The Petitioner was permitted to challenge each O-O by filing statutory appeals; any amounts already deposited are to be adjusted against pre-deposits in those appeals. Petition disposed of.
The HC dismissed the writ petition challenging three Orders-in-Original concerning demands for allegedly fraudulent availment of ITC, holding that factual determinations on fraudulent ITC cannot be adjudicated in writ jurisdiction and noting precedent from higher courts. The Court found non-entertainment of the writ appropriate and declined to interfere on merits for lack of natural justice issues warranting writ relief. The Petitioner was permitted to challenge each O-O by filing statutory appeals; any amounts already deposited are to be adjusted against pre-deposits in those appeals. Petition disposed of.
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