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...
Adjustments / additions u/s 143(1) - CPC made disallowed without considering the objections / reply filed by the assessee - Empty formality - Ld. NFAC ought to have considered the above additional documents and adjudicated the case in accordance with law. Since it is only a proceeding u/s. 143(1) and not a scrutiny assessment where assessee is expected to file all necessary documents along with the Return of Income. - Matter restored back to re-adjudicate the issue - AT
Adjustments / additions u/s 143(1) - CPC made disallowed without considering the objections / reply filed by the assessee - Empty formality - Ld. NFAC ought to have considered the above additional documents and adjudicated the case in accordance with law. Since it is only a proceeding u/s. 143(1) and not a scrutiny assessment where assessee is expected to file all necessary documents along with the Return of Income. - Matter restored back to re-adjudicate the issue - AT
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