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...
Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
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