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 HC quashed and set aside the show cause notices dated 20 October 2011 and 6 August 2012 issued to the Petitioner. The HC held that there was an unexplained delay of more than 10 years by the Respondents in adjudicating the show cause notices, and the Respondents failed to provide any justification for such inordinate delay. Consequently, following the decisions of the Coordinate Benches, the HC allowed the Petition and quashed the show cause notices due to the unreasonable delay in adjudication.
The HC quashed and set aside the show cause notices dated 20 October 2011 and 6 August 2012 issued to the Petitioner. The HC held that there was an unexplained delay of more than 10 years by the Respondents in adjudicating the show cause notices, and the Respondents failed to provide any justification for such inordinate delay. Consequently, following the decisions of the Coordinate Benches, the HC allowed the Petition and quashed the show cause notices due to the unreasonable delay in adjudication.
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