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...
Reopening of assessment u/s 147 - non-deduction of TDS as mentioned in the Form no. 3CD Tax Audit Report u/sec. 44AB - the assessee has filed the details and disclosed fully and truly all material facts relevant to the assessment year in consideration. - the assessment was reopened beyond a period of four years and cannot be sustained. - AT
Reopening of assessment u/s 147 - non-deduction of TDS as mentioned in the Form no. 3CD Tax Audit Report u/sec. 44AB - the assessee has filed the details and disclosed fully and truly all material facts relevant to the assessment year in consideration. - the assessment was reopened beyond a period of four years and cannot be sustained. - AT
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