Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
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