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 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
Reassessment u/s 147 - Sanction granted by the CIT u/s 151 - simply written “Yes I agree” which does not in any manner shed any light as to whether there was any application of mind at all by the Pr.CIT, - When a superior authority is given power by the legislature, to grant sanction to then that power needs to be exercised with due care and circumspection and after due application of mind - reassessment quashed
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