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...
Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
Reassessment beyond four years was invalid where the original scrutiny had specifically examined disallowance of expenditure relating to exempt income and the assessee had provided relevant particulars. The revenue neither alleged failure to disclose fully and truly all material facts nor identified tangible material obtained after the original assessment showing income had escaped assessment. Reopening on re-examination of the same assessment record constituted a change of opinion. The High Court quashed the reassessment notice and consequential orders.
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