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...
Claim for reimbursement of differential GST arising from rate increase from 12% to 18% was rejected on the ground that the contractual circular-based liability to bear differential tax depends on the tax rate as on invoice/payment date, and the delay in raising the invoice after issuance of the work completion certificate was attributable to the claimant rather than the principal. Consequently, denial of differential GST was upheld. The Court further held that the dispute involved contested factual issues unsuitable for adjudication under Article 226, and dismissed the writ petition while granting liberty to pursue remedies before the civil court or arbitral forum. - HC
Claim for reimbursement of differential GST arising from rate increase from 12% to 18% was rejected on the ground that the contractual circular-based liability to bear differential tax depends on the tax rate as on invoice/payment date, and the delay in raising the invoice after issuance of the work completion certificate was attributable to the claimant rather than the principal. Consequently, denial of differential GST was upheld. The Court further held that the dispute involved contested factual issues unsuitable for adjudication under Article 226, and dismissed the writ petition while granting liberty to pursue remedies before the civil court or arbitral forum. - HC
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