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...
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
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