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...
The High Court dealt with a partial rejection of a waiver claim linked to belated filing of GSTR-9 and noted the absence of a specific appellate remedy against the waiver order. As the petitioner had not appeared despite notice, the Court held that one further opportunity should be granted to file a reply and supporting documents before the same authority. It set aside the impugned order and remanded the matter for fresh consideration, leaving all factual and legal contentions open. No finding was rendered on the merits of the waiver claim under Rule 164(10), and the request was to be reconsidered in light of the clarifications in Circular No. 238/32/2024-GST.
The High Court dealt with a partial rejection of a waiver claim linked to belated filing of GSTR-9 and noted the absence of a specific appellate remedy against the waiver order. As the petitioner had not appeared despite notice, the Court held that one further opportunity should be granted to file a reply and supporting documents before the same authority. It set aside the impugned order and remanded the matter for fresh consideration, leaving all factual and legal contentions open. No finding was rendered on the merits of the waiver claim under Rule 164(10), and the request was to be reconsidered in light of the clarifications in Circular No. 238/32/2024-GST.
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