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...
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
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