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...
If the assessment order itself has been quashed then challenging the deletion of additions on merits is purely academic, because the assessment itself is quashed and held to be invalid against which there is no appeal. If the additional grounds is with regard to principle of natural justice on which ld. CIT (A) has given his remarks that also cannot be treated as additional ground. Consequently, all the grounds raised by the department is dismissed. - AT
If the assessment order itself has been quashed then challenging the deletion of additions on merits is purely academic, because the assessment itself is quashed and held to be invalid against which there is no appeal. If the additional grounds is with regard to principle of natural justice on which ld. CIT (A) has given his remarks that also cannot be treated as additional ground. Consequently, all the grounds raised by the department is dismissed. - AT
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