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 - Lack of full disclosures - Time given vide SCN dated 13.09.2021 is too short - To be noted, vide paragraph 3 of the SCN, writ petitioner-assessee was called upon to respond by 23:59 hours on 16.09.2021. 13.09.2021 is a Monday and obviously 16.09.2021 is Wednesday and that fairly three working days. It is clearly insufficient. - the impugned assessment order made by the first respondent is set aside on the grounds of lack of opportunity / specificity - Matter restored back - HC
Reopening of assessment u/s 147 - Lack of full disclosures - Time given vide SCN dated 13.09.2021 is too short - To be noted, vide paragraph 3 of the SCN, writ petitioner-assessee was called upon to respond by 23:59 hours on 16.09.2021. 13.09.2021 is a Monday and obviously 16.09.2021 is Wednesday and that fairly three working days. It is clearly insufficient. - the impugned assessment order made by the first respondent is set aside on the grounds of lack of opportunity / specificity - Matter restored back - HC
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