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...
Reopening of assessment - based on Investigation Wing report - apparently wrong facts in reasons - No primary independent enquiry - non-application of mind - notice u/s 148 is void ab-initio
Reopening of assessment - based on Investigation Wing report - apparently wrong facts in reasons - No primary independent enquiry - non-application of mind - notice u/s 148 is void ab-initio
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