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...
Permission to file a statutory appeal was considered by condoning a 478-day delay to determine admissibility; the court quashed the impugned assessment order and remitted the matter to the original authority for fresh adjudication on merits. The remand was made conditional on the petitioner depositing the entire tax amount confirmed in the assessment from its electronic cash register within thirty days of receipt of the order. The time-bar under the GST appeal regime and the deposit requirement governed the court's operative relief.
Permission to file a statutory appeal was considered by condoning a 478-day delay to determine admissibility; the court quashed the impugned assessment order and remitted the matter to the original authority for fresh adjudication on merits. The remand was made conditional on the petitioner depositing the entire tax amount confirmed in the assessment from its electronic cash register within thirty days of receipt of the order. The time-bar under the GST appeal regime and the deposit requirement governed the court's operative relief.
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