Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Rejection of the application under SVLDRS due to an ongoing investigation and non-quantification of duty as of the cut-off date, June 30, 2019. - The court observed that, summary rejection of an application without affording an opportunity of being heard would fall foul of the principles of natural justice. - The High Court directed the respondents (Revenue) to consider the declaration of the petitioner in terms of the Scheme as a valid declaration under the category of “investigation, enquiry and audit” and grant the consequential reliefs to the petitioner.
Rejection of the application under SVLDRS due to an ongoing investigation and non-quantification of duty as of the cut-off date, June 30, 2019. - The court observed that, summary rejection of an application without affording an opportunity of being heard would fall foul of the principles of natural justice. - The High Court directed the respondents (Revenue) to consider the declaration of the petitioner in terms of the Scheme as a valid declaration under the category of “investigation, enquiry and audit” and grant the consequential reliefs to the petitioner.
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