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...
Petitioner challenged validity of re-assessment u/s 148A. HC quashed impugned order and notice initiating re-assessment proceedings issued by 3rd Respondent. HC held short time of two days given to petitioner to reply after receiving Investigation Report violated principles of natural justice. Order passed in undue haste smacking arbitrariness, not following statutory provision of Section 148A. When new facts introduced in notice on 20.03.2024, at least seven days' time should have been granted to petitioner to reply, but proceedings conducted hurriedly violating natural justice.
Petitioner challenged validity of re-assessment u/s 148A. HC quashed impugned order and notice initiating re-assessment proceedings issued by 3rd Respondent. HC held short time of two days given to petitioner to reply after receiving Investigation Report violated principles of natural justice. Order passed in undue haste smacking arbitrariness, not following statutory provision of Section 148A. When new facts introduced in notice on 20.03.2024, at least seven days' time should have been granted to petitioner to reply, but proceedings conducted hurriedly violating natural justice.
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