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...
Reassessment proceedings barred by limitation period u/s 149(1)(b) of Finance Act, 2021. Impugned notice u/s 148 dated 15.04.2021 for AY 2015-16 quashed. Consequential reassessment proceedings set aside due to lack of sanction/approval for issuance of notice as per substituted Finance Act, 2021. Appellant succeeds on legal issues, decided in favor of assessee.
Reassessment proceedings barred by limitation period u/s 149(1)(b) of Finance Act, 2021. Impugned notice u/s 148 dated 15.04.2021 for AY 2015-16 quashed. Consequential reassessment proceedings set aside due to lack of sanction/approval for issuance of notice as per substituted Finance Act, 2021. Appellant succeeds on legal issues, decided in favor of assessee.
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