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...
Refusal to condone delay in filing the appeal against an intimation under Section 143(1) was upheld because the assessee had knowledge of the outstanding demand from the refund-adjustment communication and had even sought revision against that demand; the appellate authorities' concurrent factual findings that the appeal was time-barred and the delay remained unexplained showed no perversity or legal infirmity, so no substantial question of law arose under Section 260A. The assessee's claim for exemption of long-term capital gains on sale of shares was not examined on merits because the appellate remedy itself had failed on limitation. The rectification grievance was treated as an independent statutory remedy and left open.
Refusal to condone delay in filing the appeal against an intimation under Section 143(1) was upheld because the assessee had knowledge of the outstanding demand from the refund-adjustment communication and had even sought revision against that demand; the appellate authorities' concurrent factual findings that the appeal was time-barred and the delay remained unexplained showed no perversity or legal infirmity, so no substantial question of law arose under Section 260A. The assessee's claim for exemption of long-term capital gains on sale of shares was not examined on merits because the appellate remedy itself had failed on limitation. The rectification grievance was treated as an independent statutory remedy and left open.
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