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...
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Provisional attachment of a bank account under GST was discussed in the context of alleged incorrect reporting of tax liability and excess input tax credit in GSTR-9. The Court noted that the petitioner had neither filed a reply to the show cause notice nor been granted a personal hearing, and treated the right to be heard as part of natural justice. Relief was balanced by requiring deposit of the entire demand before setting aside the adjudication order and allowing fresh reply and hearing. The consequential recovery measures and bank attachment were directed to be lifted, with merits left open for de novo adjudication.
Provisional attachment of a bank account under GST was discussed in the context of alleged incorrect reporting of tax liability and excess input tax credit in GSTR-9. The Court noted that the petitioner had neither filed a reply to the show cause notice nor been granted a personal hearing, and treated the right to be heard as part of natural justice. Relief was balanced by requiring deposit of the entire demand before setting aside the adjudication order and allowing fresh reply and hearing. The consequential recovery measures and bank attachment were directed to be lifted, with merits left open for de novo adjudication.
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