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 delayed adjudication of SCN - Inordinate delay of 13 years in adjudication of SCN - We fail to understand when the respondents could wait for 13 long years after issuance of the show-cause notices, there could not have been any earthly reason to proceed at such great speed and pass the order-in-original before the Court could adjudicate on the correctness of the action of the respondents. - Such adjudication proceeding is therefore, held to be invalid - Order quashed - HC
Validity of delayed adjudication of SCN - Inordinate delay of 13 years in adjudication of SCN - We fail to understand when the respondents could wait for 13 long years after issuance of the show-cause notices, there could not have been any earthly reason to proceed at such great speed and pass the order-in-original before the Court could adjudicate on the correctness of the action of the respondents. - Such adjudication proceeding is therefore, held to be invalid - Order quashed - HC
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