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...
Validity of assessment order - non-speaking assessment order - non-application of mind - violation of principles of natural justice - reversal of ITC - The petitioner contended that the order failed to consider their submissions adequately. The High Court found merit in the petitioner's arguments, noting instances where the assessing officer failed to provide proper reasoning and overlooked relevant material. As a result, the Court quashed the order and directed a fresh assessment
Validity of assessment order - non-speaking assessment order - non-application of mind - violation of principles of natural justice - reversal of ITC - The petitioner contended that the order failed to consider their submissions adequately. The High Court found merit in the petitioner's arguments, noting instances where the assessing officer failed to provide proper reasoning and overlooked relevant material. As a result, the Court quashed the order and directed a fresh assessment
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