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...
Reassessment u/s 147 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
Reassessment u/s 147 - proceedings after expiry of 6 years - direction by court or mere observation - AO applied the provisions of section 150, when the findings of the coordinate bench are not direction but observation - proceedings initiated u/s 147 beyond 6 years are void ab-initio as per the time limit prescribed u/s 149 - assessment order quashed
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