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...
Writ petitions challenging search and seizure were held premature because the statutory investigative process had advanced to issuance of show-cause notices under the CGST Act; petitioners must first exhaust the statutory remedy and may attack any final Order-in-Original. The court applied judicial restraint, confining review of the recorded reasons to Wednesbury reasonableness and refusing to rehear administrative judgment on its merits. Requests for immediate release of goods were denied, with provisional release permitted only on production of valid bills, challans or receipts or by following the Section 67(6)/Rule 140(1) provisional-release procedure and furnishing a bond.
Writ petitions challenging search and seizure were held premature because the statutory investigative process had advanced to issuance of show-cause notices under the CGST Act; petitioners must first exhaust the statutory remedy and may attack any final Order-in-Original. The court applied judicial restraint, confining review of the recorded reasons to Wednesbury reasonableness and refusing to rehear administrative judgment on its merits. Requests for immediate release of goods were denied, with provisional release permitted only on production of valid bills, challans or receipts or by following the Section 67(6)/Rule 140(1) provisional-release procedure and furnishing a bond.
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