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...
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
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