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 notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
Validity of notice issued for re-assessment - satisfaction of requirement of section 151(2) before issuance of notice u/s 148 - it was a fit case for issuance of notice u/s 148 - Merely because the papers were thereafter for some erroneous reason also placed before the Commissioner who also recorded his similar satisfaction would not take away anything from the previous conclusion. - HC
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