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...
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
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