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...
Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
Maintainability of wrt petition before HC where option for filing Revision u/s 264 is available - Rejection of Refund of excess amount paid as tax - There are no substance in the submission of the Petitioner that no revision would be available against the impugned order as it is not an order passed under the Act. Thus, remedy of revision u/s 264(1) would be available to the Petitioner.
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