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...
Interpretation of the General Clauses Act rule excluding the first day and including the last day governs computation of "month" for statutory time-limits under the CGST regime: where an order must be passed by a specified calendar date, the terminal day is included and the day on which a process (show cause notice) is issued is excluded when counting the requisite months. Applying that rule, the three consecutive months prior to the terminal month satisfy the "at least three months" requirement for issuance of a show cause notice, rendering notices issued on or before the excluded initial date within limitation.
Interpretation of the General Clauses Act rule excluding the first day and including the last day governs computation of "month" for statutory time-limits under the CGST regime: where an order must be passed by a specified calendar date, the terminal day is included and the day on which a process (show cause notice) is issued is excluded when counting the requisite months. Applying that rule, the three consecutive months prior to the terminal month satisfy the "at least three months" requirement for issuance of a show cause notice, rendering notices issued on or before the excluded initial date within limitation.
Note: It is a system-generated summary and is for quick reference only.
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