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...
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
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