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...
Dominant issue: whether the respondent violated Section 171 CGST by not passing on Input Tax Credit (ITC) benefits. Reasoning: DGAP admitted partial pass-through of ITC (Rs. 91,45,350) but also identified a prima facie computation requiring Rs. 3,12,78,937 to be passed to 1,104 eligible home buyers; despite a reporting error, the authority held the obligation to remit the larger validated sum. Outcome: respondent ordered to pay Rs. 3,12,78,937 plus interest under Section 133(3)(B) CGST, refund within three months, and file compliance report with the jurisdictional commissioner and DGAP. - AT
Dominant issue: whether the respondent violated Section 171 CGST by not passing on Input Tax Credit (ITC) benefits. Reasoning: DGAP admitted partial pass-through of ITC (Rs. 91,45,350) but also identified a prima facie computation requiring Rs. 3,12,78,937 to be passed to 1,104 eligible home buyers; despite a reporting error, the authority held the obligation to remit the larger validated sum. Outcome: respondent ordered to pay Rs. 3,12,78,937 plus interest under Section 133(3)(B) CGST, refund within three months, and file compliance report with the jurisdictional commissioner and DGAP. - AT
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