Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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HC entertained a challenge to a composite demand-cum-show cause notice issued under Section 74 of the CGST Act, 2017 covering multiple tax periods. Observing that a coordinate bench had earlier granted a reasoned interim order in similar matters, and that no contrary view had been taken by any other bench, the HC applied the rule of consistency and noted that three other HCs had decided the issue in favour of assessees. Finding a prima facie case, the HC granted interim protection in the present and connected petitions where no interim relief had yet been granted. Application disposed.
HC entertained a challenge to a composite demand-cum-show cause notice issued under Section 74 of the CGST Act, 2017 covering multiple tax periods. Observing that a coordinate bench had earlier granted a reasoned interim order in similar matters, and that no contrary view had been taken by any other bench, the HC applied the rule of consistency and noted that three other HCs had decided the issue in favour of assessees. Finding a prima facie case, the HC granted interim protection in the present and connected petitions where no interim relief had yet been granted. Application disposed.
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