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...
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
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