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 - Assessee has failed to establish that the AO has made necessary enquiries - there is no doubt about applicability of Explanation (2) to section 263(1) of the IT Act, assessment year being 2017-18 the assessment order as well as the impugned revisionary order having been passed after aforesaid date of 01/06/2015. - Revision order sustained - AT
Revision u/s 263 - Assessee has failed to establish that the AO has made necessary enquiries - there is no doubt about applicability of Explanation (2) to section 263(1) of the IT Act, assessment year being 2017-18 the assessment order as well as the impugned revisionary order having been passed after aforesaid date of 01/06/2015. - Revision order sustained - AT
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