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 reopening of assessment - even if anything is not highlighted in the Audit Report, the Assessee has shown that this aspect viz., non-deduction of TDS on the Machine Hire Charges attracting Section 194-I of the Act was very much discussed by the AO during the original Assessment proceedings. - Thus on mere change of opinion, the AO could not have invoked the reassessment proceedings u/s 147/148 - HC
Validity of reopening of assessment - even if anything is not highlighted in the Audit Report, the Assessee has shown that this aspect viz., non-deduction of TDS on the Machine Hire Charges attracting Section 194-I of the Act was very much discussed by the AO during the original Assessment proceedings. - Thus on mere change of opinion, the AO could not have invoked the reassessment proceedings u/s 147/148 - HC
Note: It is a system-generated summary and is for quick reference only.