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...
Formal initiation under the tax demand regime requires a distinct Show Cause Notice and a Statement; a summary in FORM GST DRC-01 is supplementary and cannot substitute for the Section 73 Show Cause Notice, so attachment of a tax-determination statement to DRC-01 does not validly initiate proceedings. Documents constituting the SCN, Statement or final Order must be authenticated by the Proper Officer with electronic/digital e-signature under applicable rules; unauthenticated attachments lack legal efficacy. Where an adverse decision is contemplated, a personal hearing must be afforded as a statutory safeguard; failure to provide the mandated hearing breaches natural justice. The impugned order was set aside and fresh proceedings are permitted, with a specified exclusion for limitation.
Formal initiation under the tax demand regime requires a distinct Show Cause Notice and a Statement; a summary in FORM GST DRC-01 is supplementary and cannot substitute for the Section 73 Show Cause Notice, so attachment of a tax-determination statement to DRC-01 does not validly initiate proceedings. Documents constituting the SCN, Statement or final Order must be authenticated by the Proper Officer with electronic/digital e-signature under applicable rules; unauthenticated attachments lack legal efficacy. Where an adverse decision is contemplated, a personal hearing must be afforded as a statutory safeguard; failure to provide the mandated hearing breaches natural justice. The impugned order was set aside and fresh proceedings are permitted, with a specified exclusion for limitation.
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