Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
Draft assessment repeated in the final order without incorporating DRP directions was held invalid, because directions under section 144C bind the Assessing Officer and the final assessment must conform to them. The Tribunal, following Olympus Medical Systems (P) Ltd., treated non-conformity with the DRP procedure as rendering the final assessment order bad in law and liable to be quashed. On that basis, the impugned order was quashed as null and void, and the remaining jurisdictional and merits grounds were left unadjudicated.
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