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 - Jurisdiction to issue sanction - appropriate authority to grant approval for issuance of notice u/s. 148 - the approval for issuance of notice u/s. 148 ought not have been obtained from the Additional Commissioner of Income Tax but from the authority specifically mentioned u/s. 151(ii) of the Act - Notice quashed - HC
Reopening of assessment u/s 147 - Jurisdiction to issue sanction - appropriate authority to grant approval for issuance of notice u/s. 148 - the approval for issuance of notice u/s. 148 ought not have been obtained from the Additional Commissioner of Income Tax but from the authority specifically mentioned u/s. 151(ii) of the Act - Notice quashed - HC
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