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...
Seeking rectification of an alleged mistake - question of jurisdiction of this tribunal - error apparent on the face of record or not - The Tribunal rejected the appellant's claim, stating that it had considered the jurisdiction issue in light of previous judgments and amendments. Since both parties chose not to argue the jurisdiction issue during the hearing, the Tribunal proceeded to decide the case on its merits. - The Tribunal emphasized that when a counsel makes submissions, it is presumed to be on the instructions of the appellant. Hiring a new counsel post-judgment to raise new grounds or find fault with the previous counsel's submissions is not a valid approach.
Seeking rectification of an alleged mistake - question of jurisdiction of this tribunal - error apparent on the face of record or not - The Tribunal rejected the appellant's claim, stating that it had considered the jurisdiction issue in light of previous judgments and amendments. Since both parties chose not to argue the jurisdiction issue during the hearing, the Tribunal proceeded to decide the case on its merits. - The Tribunal emphasized that when a counsel makes submissions, it is presumed to be on the instructions of the appellant. Hiring a new counsel post-judgment to raise new grounds or find fault with the previous counsel's submissions is not a valid approach.
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