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...
Issuance of second SCN without adjudicating first SCN - Valuation - the Tribunal found merit in the Appellant's arguments. It noted that the Department had pursued two show-cause notices for the same period, despite a previous adjudication favoring the Appellant and despite legal precedent prohibiting such actions. As a result, the Tribunal set aside the order passed by the Commissioner (Appeals) and allowed the appeal, granting consequential relief to the Appellant.
Issuance of second SCN without adjudicating first SCN - Valuation - the Tribunal found merit in the Appellant's arguments. It noted that the Department had pursued two show-cause notices for the same period, despite a previous adjudication favoring the Appellant and despite legal precedent prohibiting such actions. As a result, the Tribunal set aside the order passed by the Commissioner (Appeals) and allowed the appeal, granting consequential relief to the Appellant.
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