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 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
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