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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
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Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
Composite show cause notices covering multiple assessment years are not legally sustainable where separate notices are required for each year. Applying prior Division Bench rulings, the HC quashed the consolidated notice, while preserving the respondents' liberty to issue fresh notices for the relevant assessment years. It also directed that the period from issuance of the impugned notice until receipt of the certified copy of the judgment be excluded when computing limitation in any fresh proceedings.
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