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...
Jurisdiction - power of DRI to issue SCN - when it is only a show cause notice, which could be answered properly and the adjudication if permitted would not prejudice the petitioner in any manner. In that view of the matter, the SCN without rendering final opinion upon the aspect of the jurisdiction when prima facie appears to be not without any authority of law are required to be permitted to be proceeded with. - HC
Jurisdiction - power of DRI to issue SCN - when it is only a show cause notice, which could be answered properly and the adjudication if permitted would not prejudice the petitioner in any manner. In that view of the matter, the SCN without rendering final opinion upon the aspect of the jurisdiction when prima facie appears to be not without any authority of law are required to be permitted to be proceeded with. - HC
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