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...
Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
Revision u/s 263 - CIT setting aside the second reassessment order - time limit to take action u/s 263 - the necessity for the Commissioner to have substantial grounds for considering an order as erroneous and prejudicial to the interests of the revenue - The tribunal found the section 263 order to be unjustifiable for multiple reasons, including the absence of a clear failure by the assessee to disclose fully and truly all material facts necessary for its assessment, and quashed the order. - Revision order quashed.
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