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...
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
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