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...
The Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
The Appellate Tribunal considered the validity of physical/manual filing of appeal u/s the Income Tax Rules. Assessee argued inability to e-file due to lack of assistance and incomplete requirements. Tribunal noted physical filing before due date and CBDT's extension of e-filing time limit due to difficulties. Held that physical filing was valid, directing CIT(A) to admit and decide the appeal on merits, providing ample hearing opportunity to the assessee. Remanded the matter for fresh consideration.
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