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...
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The Delhi High Court dismissed the appeal challenging the findings of the Single Judge on the limitation period for a suit. The appellant did not dispute the legal findings that the deposit of TDS triggers a fresh limitation period u/s 19 of the Act of 1963. The appellant raised a factual dispute regarding a transaction reflected in the TDS certificate, claiming it pertained to a separate transaction. The court rejected this claim as it was not raised before the Single Judge. The court held that the Single Judge's conclusion based on the TDS certificate was in line with the evidence and law. The court dismissed the appeal and pending applications, affirming the Single Judge's decision on the limitation issue.
The Delhi High Court dismissed the appeal challenging the findings of the Single Judge on the limitation period for a suit. The appellant did not dispute the legal findings that the deposit of TDS triggers a fresh limitation period u/s 19 of the Act of 1963. The appellant raised a factual dispute regarding a transaction reflected in the TDS certificate, claiming it pertained to a separate transaction. The court rejected this claim as it was not raised before the Single Judge. The court held that the Single Judge's conclusion based on the TDS certificate was in line with the evidence and law. The court dismissed the appeal and pending applications, affirming the Single Judge's decision on the limitation issue.
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