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...
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
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