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 proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
Petitioner proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
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