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...
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Reopening of assessment u/s 147 - Reason to believe - The objective satisfaction would be sufficient for the purpose of allowing the Assessing authority to proceed with the reopening proceedings. - The reasons furnished in the case of the petitioner would be sufficient for the purpose of reopening of assessment as the case of the petitioner is initiated beyond a period of four years, but within a period of six years and therefore, the petitioner is bound to participate in the reopening proceedings for the purpose of defending their case - HC
Reopening of assessment u/s 147 - Reason to believe - The objective satisfaction would be sufficient for the purpose of allowing the Assessing authority to proceed with the reopening proceedings. - The reasons furnished in the case of the petitioner would be sufficient for the purpose of reopening of assessment as the case of the petitioner is initiated beyond a period of four years, but within a period of six years and therefore, the petitioner is bound to participate in the reopening proceedings for the purpose of defending their case - HC
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