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...
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
Non-consideration of the assessee's replies before issuing a reassessment notice can vitiate the order where the statute requires those explanations to be examined before forming a view on escaped income. The text notes that the impugned order dealt only partially with the materials filed and did not analyse the commercial rationale or the specific explanations offered, so the formation of belief lacked a sustainable basis. The order and consequential notice were quashed, and the matter was remitted for fresh consideration after granting an opportunity of hearing and passing a reasoned order.
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