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...
Inadvertence claim untenable, delay in rectifying alleged error reflects absence of inadvertence. Petitioner withdrew higher value complaint, pursued lower value complaint, then approached mediation without realizing inadvertence. Petitioner revived execution petition for arbitral award recovery instead of complaint cases, indicating deliberate choice. Application u/s 362 CrPC for recall filed belatedly after six months, dismissed by magistrate. Conduct inconsistent with inadvertence claim. Petition dismissed for lack of merit.
Inadvertence claim untenable, delay in rectifying alleged error reflects absence of inadvertence. Petitioner withdrew higher value complaint, pursued lower value complaint, then approached mediation without realizing inadvertence. Petitioner revived execution petition for arbitral award recovery instead of complaint cases, indicating deliberate choice. Application u/s 362 CrPC for recall filed belatedly after six months, dismissed by magistrate. Conduct inconsistent with inadvertence claim. Petition dismissed for lack of merit.
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