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...
Transfer of case - Validity of the assessment orders passed by the Additional CIT u/s 143(1) - Lack of inherent jurisdiction - The assessment order has been passed by the Addl.CIT without any transfer of jurisdiction in his favour - the assessment order passed by him u/s 143(3) is without jurisdiction, illegal, bad in law and hence ought to be quashed. - AT
Transfer of case - Validity of the assessment orders passed by the Additional CIT u/s 143(1) - Lack of inherent jurisdiction - The assessment order has been passed by the Addl.CIT without any transfer of jurisdiction in his favour - the assessment order passed by him u/s 143(3) is without jurisdiction, illegal, bad in law and hence ought to be quashed. - AT
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