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...
Summons u/s 131 - In the considered opinion of this Court, the impugned summons to the extent of asking the assessee to be present for unlimited period till the time he obtains permission from the Assistant Commissioner, is highly unreasonable. Though there is no infirmity in asking the petitioner to be present for enquiry, this Court does not find any justification on the part of the Assistant Commissioner in asking the assessee to be present for unlimited period.
Summons u/s 131 - In the considered opinion of this Court, the impugned summons to the extent of asking the assessee to be present for unlimited period till the time he obtains permission from the Assistant Commissioner, is highly unreasonable. Though there is no infirmity in asking the petitioner to be present for enquiry, this Court does not find any justification on the part of the Assistant Commissioner in asking the assessee to be present for unlimited period.
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