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 quashed consolidated show-cause notices issued by Respondent No.2 that clubbed multiple financial years for demand of GST and reversal of alleged ineligible ITC, holding such consolidation to be without jurisdiction and a judicial overreach. The court reaffirmed the statutory limitation scheme under the CGST Act, 2017 - tax periods are tied to returns (monthly or annual) and demands must respect the time limits in Sections 73 and 74 - so SCNs must be framed with reference to discrete financial years. Prior observations by a coordinate bench were noted but the HC granted the petition and set aside the impugned consolidated notices.
The HC quashed consolidated show-cause notices issued by Respondent No.2 that clubbed multiple financial years for demand of GST and reversal of alleged ineligible ITC, holding such consolidation to be without jurisdiction and a judicial overreach. The court reaffirmed the statutory limitation scheme under the CGST Act, 2017 - tax periods are tied to returns (monthly or annual) and demands must respect the time limits in Sections 73 and 74 - so SCNs must be framed with reference to discrete financial years. Prior observations by a coordinate bench were noted but the HC granted the petition and set aside the impugned consolidated notices.
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