Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
An AO must pass the final assessment order in conformity with the DRP's directions under section 144C(13); any departure, even if said to be due to mistake or misunderstanding, is impermissible. Applying binding High Court precedent, the Tribunal quashed the non-compliant final assessment order because the AO repeated the draft order and ignored the relief granted by the DRP. The transfer pricing and consequential grounds were left open as academic.
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