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 quashed the impugned appellate order, holding the petitioner-a SEZ unit-entitled to refund of unutilized IGST credit in the Electronic Credit Ledger under s.54 of the CGST Act. The Court affirmed that the input service distributor concept permits recognition of input tax credit on services received for zero-rated supplies, and applied controlling HC precedent which remains operative and unstayed. Consequently, respondents were directed to process the petitioner's refund claim forthwith. The writ succeeds, the appellate order dated 18.02.2025 is set aside, and relief is granted to effect reimbursement of the unutilized IGST credit.
The HC allowed the petition and quashed the impugned appellate order, holding the petitioner-a SEZ unit-entitled to refund of unutilized IGST credit in the Electronic Credit Ledger under s.54 of the CGST Act. The Court affirmed that the input service distributor concept permits recognition of input tax credit on services received for zero-rated supplies, and applied controlling HC precedent which remains operative and unstayed. Consequently, respondents were directed to process the petitioner's refund claim forthwith. The writ succeeds, the appellate order dated 18.02.2025 is set aside, and relief is granted to effect reimbursement of the unutilized IGST credit.
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