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...
Rectification relating to export refund was rejected without considering documents evidencing realization of export proceeds, thereby breaching natural justice. The record showed the documents were in fact produced with the representation, and the authority failed to address them while deciding rectification. Applying prior binding precedent on illegality and lack of authority in similar refund/rectification rejection, the impugned order was set aside and the matter remitted for fresh consideration of the rectification application in accordance with law; the writ petition was partly allowed. - HC
Rectification relating to export refund was rejected without considering documents evidencing realization of export proceeds, thereby breaching natural justice. The record showed the documents were in fact produced with the representation, and the authority failed to address them while deciding rectification. Applying prior binding precedent on illegality and lack of authority in similar refund/rectification rejection, the impugned order was set aside and the matter remitted for fresh consideration of the rectification application in accordance with law; the writ petition was partly allowed. - HC
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