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...
Validity of SCN - no specific findings have been recorded regarding the involvement of the appellant in any fraudulent activities concerning fraud, collusion, miss-appropriation etc. with intent to evade payment of duty - SCN could not be issued u/s 11A invoking expended period of limitation - demand set aside - AT
Validity of SCN - no specific findings have been recorded regarding the involvement of the appellant in any fraudulent activities concerning fraud, collusion, miss-appropriation etc. with intent to evade payment of duty - SCN could not be issued u/s 11A invoking expended period of limitation - demand set aside - AT
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