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...
For assessments under section 153C, the limitation period is stated to commence when the other person's records are transferred to the Assessing Officer handling the searched group under section 127. The subsequent recording of a satisfaction note does not postpone that commencement. Applying this principle, the reported Tribunal decision treated the assessments for the relevant assessment years as time-barred and quashed them, while leaving the remaining grounds open.
For assessments under section 153C, the limitation period is stated to commence when the other person's records are transferred to the Assessing Officer handling the searched group under section 127. The subsequent recording of a satisfaction note does not postpone that commencement. Applying this principle, the reported Tribunal decision treated the assessments for the relevant assessment years as time-barred and quashed them, while leaving the remaining grounds open.
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