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...
Stay petition - prima facie case - on objections being filed by the assessee, the AO disposed of the objections then in appeal the CIT(A) ought to have considered the validity of the reopening and not rejected the appeal on the ground that the assessee participated in response to the notice issued u/s 148 - this would be sufficient to hold that the assessee has made out a prima facie case
Stay petition - prima facie case - on objections being filed by the assessee, the AO disposed of the objections then in appeal the CIT(A) ought to have considered the validity of the reopening and not rejected the appeal on the ground that the assessee participated in response to the notice issued u/s 148 - this would be sufficient to hold that the assessee has made out a prima facie case
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