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...
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
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