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...
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
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