Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The High Court quashed the show cause notices and orders issued by the revenue authorities due to inordinate delay ranging from 9 to 20 years in adjudicating the notices, without any justifiable reason. The Court relied on its previous decisions and the Bombay High Court's judgment in Coventry Estates Pvt. Ltd. case, holding that such substantial delay nullifies the noticee's rights and causes irreparable prejudice. Consequently, the show cause notices and orders were quashed and set aside on the ground of non-justification for the delay in adjudication.
The High Court quashed the show cause notices and orders issued by the revenue authorities due to inordinate delay ranging from 9 to 20 years in adjudicating the notices, without any justifiable reason. The Court relied on its previous decisions and the Bombay High Court's judgment in Coventry Estates Pvt. Ltd. case, holding that such substantial delay nullifies the noticee's rights and causes irreparable prejudice. Consequently, the show cause notices and orders were quashed and set aside on the ground of non-justification for the delay in adjudication.
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