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...
Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
Once the original reassessment orders u/s 148 were quashed, they ceased to exist legally. The rectification order u/s 154 was premised on the quashed orders, which could not be revived or corrected. Section 154 could only be invoked if a valid order capable of rectification existed. Since the original orders were non-existent after being quashed, invoking Section 154 was impermissible. Additionally, the condition u/s 149(1)(b) requiring income escaping assessment to be Rs. 50 lakhs or more was not fulfilled. Consequently, the rectification order was unsustainable and quashed by the High Court.
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