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...
Rule 86A permits only a temporary restriction on debit of credit actually available in the Electronic Credit Ledger; it does not authorise the Commissioner or an authorised officer to create a negative balance by blocking more credit than stands to the taxpayer's account. The High Court also reiterated that prior show cause notice is not required before invoking Rule 86A, because the measure is preventive and intended for emergent situations, but that does not enlarge the statutory power. The impugned blocking beyond the available credit was unsustainable and was set aside, while the authorities were left free to pursue recovery through the statutory mechanisms available in law.
Rule 86A permits only a temporary restriction on debit of credit actually available in the Electronic Credit Ledger; it does not authorise the Commissioner or an authorised officer to create a negative balance by blocking more credit than stands to the taxpayer's account. The High Court also reiterated that prior show cause notice is not required before invoking Rule 86A, because the measure is preventive and intended for emergent situations, but that does not enlarge the statutory power. The impugned blocking beyond the available credit was unsustainable and was set aside, while the authorities were left free to pursue recovery through the statutory mechanisms available in law.
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