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...
Condonation of delay in filling appeal before CIT(A) - CIT(A) dismissing the appeal of the assessee in-limine - The Appellate Tribunal recognized the appellant's explanation for the delay, noting that notices were sent to an outdated address, and the appellant became aware of the assessment order only when a lien was placed on their bank account. Considering the extraordinary circumstances, including the COVID-19 pandemic, the Tribunal condoned the delay and allowed the appeal. Recognizing the appellant's right to proper representation, the Tribunal ordered the restoration of all issues to the AO's file for re-examination, emphasizing the need for adequate opportunity and cooperation from the appellant.
Condonation of delay in filling appeal before CIT(A) - CIT(A) dismissing the appeal of the assessee in-limine - The Appellate Tribunal recognized the appellant's explanation for the delay, noting that notices were sent to an outdated address, and the appellant became aware of the assessment order only when a lien was placed on their bank account. Considering the extraordinary circumstances, including the COVID-19 pandemic, the Tribunal condoned the delay and allowed the appeal. Recognizing the appellant's right to proper representation, the Tribunal ordered the restoration of all issues to the AO's file for re-examination, emphasizing the need for adequate opportunity and cooperation from the appellant.
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