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...
Principles of natural justice violated due to lack of jurisdiction and non-application of mind. Reverse Charge Mechanism (RCM) liability issue: Petitioner's reply on amounts declared and paid under RCM greater than notice amount disregarded. Trade payables issue: Petitioner's reply on all trade payables below 180 days ignored without consideration. Impugned order reflecting non-application of mind, non-consideration of petitioner's reply. Order set aside, matter remanded for reconsideration. Petition disposed by way of remand.
Principles of natural justice violated due to lack of jurisdiction and non-application of mind. Reverse Charge Mechanism (RCM) liability issue: Petitioner's reply on amounts declared and paid under RCM greater than notice amount disregarded. Trade payables issue: Petitioner's reply on all trade payables below 180 days ignored without consideration. Impugned order reflecting non-application of mind, non-consideration of petitioner's reply. Order set aside, matter remanded for reconsideration. Petition disposed by way of remand.
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