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...
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
Faceless assessment procedure requires a meaningful opportunity of personal hearing where sought, including access to video-conference facilities. The text records a prima facie concern that, after the assessee could not access the video-conference link because of a technical glitch, no further personal-hearing opportunity was provided before the assessment order was issued. It identifies possible non-compliance with the hearing procedure under the faceless assessment framework. The Revenue was given time to verify whether the final additions exceeded those proposed in the show-cause notice and whether video-conference access had been provided during the relevant period; the matter was listed for further instructions.
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