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...
Validity of assessment orders - Allegation that freight not reported and goods sold with under value - The court finds that the assessing officer's determination of suppressed freight charges lacks a rational basis. The freight charges attributed by the assessing officer are significantly higher than the actual consignment values, indicating flawed reasoning. Additionally, the court notes that the reliance on information gathered from the Internet without specifying its nature raises doubts about the credibility of the assessment orders. - Matter restored back for fresh consideration.
Validity of assessment orders - Allegation that freight not reported and goods sold with under value - The court finds that the assessing officer's determination of suppressed freight charges lacks a rational basis. The freight charges attributed by the assessing officer are significantly higher than the actual consignment values, indicating flawed reasoning. Additionally, the court notes that the reliance on information gathered from the Internet without specifying its nature raises doubts about the credibility of the assessment orders. - Matter restored back for fresh consideration.
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