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...
Maintainability of appeal - appeal dismissed at the admission stage on the ground that it was barred by limitation and beyond the condonable statutory period - The court found merit in the petitioner's submissions regarding health issues causing the delay in filing the appeal, as supported by affidavits and documentary evidence. Despite the absence of illegality in the impugned order, the court invoked its writ jurisdiction to ensure justice by condoning the delay and allowing the appeal to proceed.
Maintainability of appeal - appeal dismissed at the admission stage on the ground that it was barred by limitation and beyond the condonable statutory period - The court found merit in the petitioner's submissions regarding health issues causing the delay in filing the appeal, as supported by affidavits and documentary evidence. Despite the absence of illegality in the impugned order, the court invoked its writ jurisdiction to ensure justice by condoning the delay and allowing the appeal to proceed.
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