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...
Entitlement to input tax credit under the law survives despite a limitation clause: the retrospective amendment and extension of the deadline to claim ITC enable claims within the extended window, and assessment orders denying ITC solely on limitation grounds are quashed accordingly, with relief directed to refund or permit adjustment of amounts taken from taxpayers' ledgers. The revenue is restrained from recovery or account freezing based on limitation-only disallowances. The department retains the right to investigate and act where alleged fraud, wrongful or excess ITC claims, or discrepancies are shown, and may proceed against taxpayers on those substantive grounds.
Entitlement to input tax credit under the law survives despite a limitation clause: the retrospective amendment and extension of the deadline to claim ITC enable claims within the extended window, and assessment orders denying ITC solely on limitation grounds are quashed accordingly, with relief directed to refund or permit adjustment of amounts taken from taxpayers' ledgers. The revenue is restrained from recovery or account freezing based on limitation-only disallowances. The department retains the right to investigate and act where alleged fraud, wrongful or excess ITC claims, or discrepancies are shown, and may proceed against taxpayers on those substantive grounds.
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