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 Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
Validity of Search u/s 132 - suppression of income as the profit declared is contrary to the actual profit received. - The power for re-assessment is no doubt a remedy available to the Authority but in light of the information as detailed in the note, grounds have been made out for exercise of power u/s 132(c) in the present case and it cannot be said that the said action is either malafide/ arbitrary/ capricious. - HC
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