Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
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