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...
Jurisdiction for passing adjudication order - when there is a clear observation of the hon’ble High Court in the present case itself that will prevail over the board circular which was relied upon by the learned Commissioner (Appeals) - the observation of hon’ble High Court will prevail over the board circular and according to which the Joint Commissioner has jurisdiction not only to issue the Show Cause Notice but also to adjudicate the same. - AT
Jurisdiction for passing adjudication order - when there is a clear observation of the hon’ble High Court in the present case itself that will prevail over the board circular which was relied upon by the learned Commissioner (Appeals) - the observation of hon’ble High Court will prevail over the board circular and according to which the Joint Commissioner has jurisdiction not only to issue the Show Cause Notice but also to adjudicate the same. - AT
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