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 dominant issue was whether multiple tax periods/financial years could be clubbed in a single/composite show cause notice under Sections 73/74 of the CGST/KGST Act. Relying on its earlier precedent, the Court held that such clubbing/consolidation/bunching is illegal, invalid, impermissible, and without jurisdiction, being contrary to the CGST/KGST Act; consequently, the composite show cause notice and its addendum were quashed. All consequential communications, the subsequent orders including the order-in-original, and all further proceedings pursuant to the impugned notice were also quashed, and the writ petition was allowed. - HC
The dominant issue was whether multiple tax periods/financial years could be clubbed in a single/composite show cause notice under Sections 73/74 of the CGST/KGST Act. Relying on its earlier precedent, the Court held that such clubbing/consolidation/bunching is illegal, invalid, impermissible, and without jurisdiction, being contrary to the CGST/KGST Act; consequently, the composite show cause notice and its addendum were quashed. All consequential communications, the subsequent orders including the order-in-original, and all further proceedings pursuant to the impugned notice were also quashed, and the writ petition was allowed. - HC
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