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...
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
Validity of reassessment proceedings - non-affording the petitioner an opportunity of being heard as mandated u/s 148A(b) - The court dismissed the Revenue's appeal, affirming the judgment of the learned Single Judge. It held that the requirement of providing an opportunity of being heard includes the right to a personal hearing, as mandated by Section 148A of the Income Tax Act. - The HC has also taken note of the amendment to the provisions of Section 148A(b) through the Finance Act, 2022 with effect from 1.4.2022.
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