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...
Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ - the ld. CIT(A) while adjudicating the legal issue of the validity of the satisfaction note prepared by the AO to invoke 153C against the assessee foundation, cannot resort to post mortem and resurrect a bad satisfaction note because AO could not have usurped the jurisdiction u/s 153C without preparing a valid Satisfaction Note and therefore AO’s action to invoke the jurisdiction u/s 153C in respect of AY 2014-15 was ab-initio void - AT
Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ - the ld. CIT(A) while adjudicating the legal issue of the validity of the satisfaction note prepared by the AO to invoke 153C against the assessee foundation, cannot resort to post mortem and resurrect a bad satisfaction note because AO could not have usurped the jurisdiction u/s 153C without preparing a valid Satisfaction Note and therefore AO’s action to invoke the jurisdiction u/s 153C in respect of AY 2014-15 was ab-initio void - AT
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