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...
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
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