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...
Petitioner's failure to rectify discrepant GSTR-1 entries within the prescribed rectification window (deadline 20.10.2020) meant the short payment of CGST and SGST was recoverable under Section 73(9); the Assessing Officer's tax demand of Rs. 4,38,566 with interest and penalty was upheld. Excess availment of Input Tax Credit beyond GSTR-2A (Rs. 11,374) constituted wrongful ITC, warranting penalty which was imposed after deposit. The writ was dismissed and the recovery proceedings sustained. - HC
Petitioner's failure to rectify discrepant GSTR-1 entries within the prescribed rectification window (deadline 20.10.2020) meant the short payment of CGST and SGST was recoverable under Section 73(9); the Assessing Officer's tax demand of Rs. 4,38,566 with interest and penalty was upheld. Excess availment of Input Tax Credit beyond GSTR-2A (Rs. 11,374) constituted wrongful ITC, warranting penalty which was imposed after deposit. The writ was dismissed and the recovery proceedings sustained. - HC
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