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...
Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
Retrospective insertion of Section 147A altered the foundation of the earlier order quashing reassessment notices, so the HC set aside that order and remitted the matter for fresh consideration. Relying on the Supreme Court's subsequent orders in identical matters, the Court declined to examine the merits and kept open all questions on validity, scope, effect, retrospectivity and applicability of the amended provision. Liberty was granted to the assessee to challenge Section 147A and connected or consequential provisions within the permitted time as part of the remand arrangement.
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