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...
Statutory appeals were rejected as time-barred because the delay exceeded the condonable period, and the High Court found no legal basis to interfere with that appellate rejection. The dispute concerned GST assessment orders arising from return mismatches, with intimations already issued, so no further interference was warranted on that record. However, on the petitioners' express consent, the Court directed fresh adjudication on merits after payment of the balance disputed tax or required disputed tax, as applicable, and filing replies with supporting documents; the impugned orders were treated as addenda to the show cause notices. Any bank attachment was to stand vacated only upon compliance with those conditions.
Statutory appeals were rejected as time-barred because the delay exceeded the condonable period, and the High Court found no legal basis to interfere with that appellate rejection. The dispute concerned GST assessment orders arising from return mismatches, with intimations already issued, so no further interference was warranted on that record. However, on the petitioners' express consent, the Court directed fresh adjudication on merits after payment of the balance disputed tax or required disputed tax, as applicable, and filing replies with supporting documents; the impugned orders were treated as addenda to the show cause notices. Any bank attachment was to stand vacated only upon compliance with those conditions.
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