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...
Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
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