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...
Appellate enhancement of petitioner's taxable-turnover without prior notice breached natural justice because the turnover issue was not raised by the adjudicating authority and thus was not before the appellate forum; applying the second proviso to section 107(11) (Act of 2017), the appellate addition cannot stand-consequence: that portion is set aside and remitted. The appellate authority also failed to apply its mind by mechanically relying on a figure from GSTR-3B without considering corrected figures in GSTR-9/GSTR-9C; consequence: the matter is remanded for fresh consideration after affording the petitioner an opportunity to be heard. - HC
Appellate enhancement of petitioner's taxable-turnover without prior notice breached natural justice because the turnover issue was not raised by the adjudicating authority and thus was not before the appellate forum; applying the second proviso to section 107(11) (Act of 2017), the appellate addition cannot stand-consequence: that portion is set aside and remitted. The appellate authority also failed to apply its mind by mechanically relying on a figure from GSTR-3B without considering corrected figures in GSTR-9/GSTR-9C; consequence: the matter is remanded for fresh consideration after affording the petitioner an opportunity to be heard. - HC
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