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...
Violation of natural justice by non-issuance of intimation in Form GST DRC-01A under amended Rule 142(1A) was examined through the prejudice test: since Rule 142(1A) does not mandate a 'period' and the petitioner failed to demonstrate any actual prejudice from non-issuance, the impugned show-cause notice and Order-in-Original were not set aside. The court treated the New Morning Star Travels decision as sub silentio on prejudice, affirmed availability of efficacious statutory remedy of appeal, and declined to exercise discretionary writ jurisdiction, dismissing the petition.
Violation of natural justice by non-issuance of intimation in Form GST DRC-01A under amended Rule 142(1A) was examined through the prejudice test: since Rule 142(1A) does not mandate a 'period' and the petitioner failed to demonstrate any actual prejudice from non-issuance, the impugned show-cause notice and Order-in-Original were not set aside. The court treated the New Morning Star Travels decision as sub silentio on prejudice, affirmed availability of efficacious statutory remedy of appeal, and declined to exercise discretionary writ jurisdiction, dismissing the petition.
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