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...
HC dismissed the writ petition as misconceived and premature, declining to exercise extraordinary jurisdiction where statutory authorities remain seised of ongoing investigation into transactions between the petitioner and the named suppliers. The court refused to make factual findings or to issue a mandamus directing unblocking of the electronic credit ledger, noting the blocking is confined to specified ITC claims and that no prejudice to the petitioner during the DGGI investigation was demonstrated. Absent final adjudication by the competent authority, the HC refused to usurp fact-finding functions and dismissed the petition without ordering restoration of the blocked input tax credit.
HC dismissed the writ petition as misconceived and premature, declining to exercise extraordinary jurisdiction where statutory authorities remain seised of ongoing investigation into transactions between the petitioner and the named suppliers. The court refused to make factual findings or to issue a mandamus directing unblocking of the electronic credit ledger, noting the blocking is confined to specified ITC claims and that no prejudice to the petitioner during the DGGI investigation was demonstrated. Absent final adjudication by the competent authority, the HC refused to usurp fact-finding functions and dismissed the petition without ordering restoration of the blocked input tax credit.
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