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...
Revision u/s 263 by CIT - no discussion or elaborate discussion in the assessment order - It is for the Tax Authorities to ensure that the Assessing Officers are well instructed to write the order elaborating the issues enquired into; the evidences considered to allow the claim and also discussions on how the claim is rejected. The assessee has no role to play as how the assessment orders are written. - AT
Revision u/s 263 by CIT - no discussion or elaborate discussion in the assessment order - It is for the Tax Authorities to ensure that the Assessing Officers are well instructed to write the order elaborating the issues enquired into; the evidences considered to allow the claim and also discussions on how the claim is rejected. The assessee has no role to play as how the assessment orders are written. - AT
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