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...
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
Validity of reassessment notices under sections 148 and 148A was not examined on merits because the HC followed the Supreme Court's approach in an identical matter after insertion of section 147A. The writ appeals were allowed, the Single Judge's orders were set aside, and the matters were remitted for fresh consideration. The assessees were given liberty to amend the writ petitions to challenge section 147A and any connected or consequential provision, with all rival contentions left open for decision on remand.
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