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...
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AO suo-moto framed the order u/s. 154 and rectified the order - AO framed order u/s. 154 of the Act without affording a reasonable and adequate opportunity of being heard to the assessee, also without being directed by CIT(A) - The Tribunal dismissed the appeal of the Revenue, stating that the AO assumed powers conferred upon him by section 154 of the Act without affording any opportunity of being heard to the assessee. Therefore, the Tribunal upheld the CIT(A)'s decision.
AO suo-moto framed the order u/s. 154 and rectified the order - AO framed order u/s. 154 of the Act without affording a reasonable and adequate opportunity of being heard to the assessee, also without being directed by CIT(A) - The Tribunal dismissed the appeal of the Revenue, stating that the AO assumed powers conferred upon him by section 154 of the Act without affording any opportunity of being heard to the assessee. Therefore, the Tribunal upheld the CIT(A)'s decision.
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