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...
Reassessment against a converted non-existing firm was jurisdictionally defective where no notice under section 148 was issued to the successor company and the proceedings were continued in the erstwhile firm's name. The HC also held that mandatory faceless assessment procedure was breached because no draft assessment order was issued under section 144B and a final order was passed directly. The reassessment order, demand notice and penalty notices were quashed, with liberty to proceed afresh in accordance with law after curing these defects.
Reassessment against a converted non-existing firm was jurisdictionally defective where no notice under section 148 was issued to the successor company and the proceedings were continued in the erstwhile firm's name. The HC also held that mandatory faceless assessment procedure was breached because no draft assessment order was issued under section 144B and a final order was passed directly. The reassessment order, demand notice and penalty notices were quashed, with liberty to proceed afresh in accordance with law after curing these defects.
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