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...
Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
Transfer of jurisdiction from Faridabad to Delhi was held invalid because the assessee was not given a reasonable opportunity of being heard before the transfer order was made. Notices under section 143(2) issued by Delhi officers were therefore treated as without valid jurisdiction and ineffective for the assessment year concerned. After the transfer order was cancelled, jurisdiction reverted to the original Assessing Officer at Faridabad, but that officer also completed the assessment without first issuing a valid section 143(2) notice. The assessment was consequently quashed for a foundational jurisdictional defect, and the merits were left undecided.
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