Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Validity of the decision High Court deciding the appeal on admission state itself on merit - The Supreme Court observed that while the High Court had framed certain substantial questions of law, it should not have precluded the substantial questions of law concerning the extended period of limitation and penalty at the admission stage. The Supreme Court held that not allowing these questions to be raised could prejudice the appellant's case during the final adjudication. - Matter restored back before HC for to consider the matter afresh.
Validity of the decision High Court deciding the appeal on admission state itself on merit - The Supreme Court observed that while the High Court had framed certain substantial questions of law, it should not have precluded the substantial questions of law concerning the extended period of limitation and penalty at the admission stage. The Supreme Court held that not allowing these questions to be raised could prejudice the appellant's case during the final adjudication. - Matter restored back before HC for to consider the matter afresh.
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