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 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section 151, as it stood during the assessment year 2017-18, i.e. the year in which reasons were recorded by the AO for reopening the assessment and notice u/s 148 was issued, will be applicable and thus, we find no infirmity in the sanction granted by PCIT u/s 151 in the present case. - AT
Reopening of assessment u/s 147 after 4 years - Validity of Sanction for issue of notice u/s 151 - respectfully following the aforesaid decision provisions of section 151, as it stood during the assessment year 2017-18, i.e. the year in which reasons were recorded by the AO for reopening the assessment and notice u/s 148 was issued, will be applicable and thus, we find no infirmity in the sanction granted by PCIT u/s 151 in the present case. - AT
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