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 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
Reopening of assessment u/s 147 - Notice issued on the basis of statement recorded during survey u/s 133A - The High court observed that the survey conducted led to several factual findings essential for initiating the proceedings u/s 148A. It was noted that the statement of one of the partners, was not the sole basis for the proceedings and that other evidence arising from the survey was also considered. The court also acknowledged that a statement was recorded under Section 131, which has the same powers as a civil court, including examining individuals under oath. - Consequently, High Court refused to interfere.
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