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 order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
An order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
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