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...
Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
Applicability of Circular No.224/18/2024-GST para 6 turns on two preconditions: deposit of the pre-deposit contemplated under Section 112 and provision of an undertaking/intimation to the proper appellate authority. The court accepted that the taxpayer furnished the required intimation and, in the peculiar facts, treated that intimation as sufficient for para 6; accordingly the revenue was directed to refund amounts recovered under the summary demand after withholding the pre-deposit amount as contemplated under Section 112. The taxpayer forewent any claim to interest on the refunded amount.
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