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...
Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
Rejection of SVLDRS-1 -Quantifiation of demand - It is evident that there was a quantification by the audit Department on 31.05.2019 based on which the petitioner has filed Form SVLDRS-1 dated 07.11.2019 under the category "Investigation, Enquiry or Audit" Subcategory Audit. It cannot therefore be construed that there was no determination of tax liability of the petitioner on or before 30.06.2019. - Application directed to be accepted. - HC
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