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...
Clubbing multiple tax periods/financial years (2019-20 to 2021-22) into a single composite show cause notice under ss. 73/74 of the CGST/KGST Act for reversal of input tax credit was held invalid, as such bunching had already been declared illegal in an earlier binding decision. Since the proceedings were founded on an impermissible consolidated notice, the consequential adjudication order could not survive. The composite show cause notice and the ensuing order were quashed, and the respondent was directed to drop the proceedings; the petition was allowed. - HC
Clubbing multiple tax periods/financial years (2019-20 to 2021-22) into a single composite show cause notice under ss. 73/74 of the CGST/KGST Act for reversal of input tax credit was held invalid, as such bunching had already been declared illegal in an earlier binding decision. Since the proceedings were founded on an impermissible consolidated notice, the consequential adjudication order could not survive. The composite show cause notice and the ensuing order were quashed, and the respondent was directed to drop the proceedings; the petition was allowed. - HC
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