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...
Validity of assessment - non-service of the notice u/s.143(2) - It is also clear from the record that the assessee has raised this issue first time before us, however, the documents which were produced before us, did not speak that the assessee has raised this issue before the lower authorities. CIT DR has produced sufficient evidences for substantiating the case in favour of Revenue - Argument of assessee rejected - AT
Validity of assessment - non-service of the notice u/s.143(2) - It is also clear from the record that the assessee has raised this issue first time before us, however, the documents which were produced before us, did not speak that the assessee has raised this issue before the lower authorities. CIT DR has produced sufficient evidences for substantiating the case in favour of Revenue - Argument of assessee rejected - AT
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