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...
The High Court set aside the order u/s 119(2)(b) of the Act, finding that the authority took a restrictive and conservative approach in not noticing the Central Board of Direct Taxes (CBDT) circular dated 09.06.2015 regarding condonation of delay up to six years. The matter was remitted back to the authority to reconsider, taking note of the CBDT circular. The authority must take a holistic view and pass appropriate orders expeditiously, as the period sought to be condoned is within six years, and the restriction on non-condonation applies only beyond six years.
The High Court set aside the order u/s 119(2)(b) of the Act, finding that the authority took a restrictive and conservative approach in not noticing the Central Board of Direct Taxes (CBDT) circular dated 09.06.2015 regarding condonation of delay up to six years. The matter was remitted back to the authority to reconsider, taking note of the CBDT circular. The authority must take a holistic view and pass appropriate orders expeditiously, as the period sought to be condoned is within six years, and the restriction on non-condonation applies only beyond six years.
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