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 - The assessee in its support had complied the requirements as raised by both the revenue authorities. Though the assessment order does not patently indicate that the issue in question had been considered by the AO, the record showed that the AO had applied his mind - Thus investigation by the ld. AO cannot be called ‘lack of investigation’. - AT
Revision u/s 263 by CIT - The assessee in its support had complied the requirements as raised by both the revenue authorities. Though the assessment order does not patently indicate that the issue in question had been considered by the AO, the record showed that the AO had applied his mind - Thus investigation by the ld. AO cannot be called ‘lack of investigation’. - AT
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