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...
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
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