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 - reason to believe - the onus would be on the AO to provide reasons to disbelieve the bank statements and supporting documents for reopening the assessment. That in our view has not been spelled out and therefore, the reassessment sought to be initiated deserves to be stalled. - AO has acted in excess of the limit of his jurisdiction to reopen the assessment - HC
Reopening of assessment u/s 147 - reason to believe - the onus would be on the AO to provide reasons to disbelieve the bank statements and supporting documents for reopening the assessment. That in our view has not been spelled out and therefore, the reassessment sought to be initiated deserves to be stalled. - AO has acted in excess of the limit of his jurisdiction to reopen the assessment - HC
Note: It is a system-generated summary and is for quick reference only.