Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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The HC set aside the impugned order dated 9 March 2009 passed by the Special Director (Enforcement) due to inordinate and unexplained delay between the conclusion of arguments and pronouncement of the order. The matter was remanded to the Special Director (Enforcement) to dispose of the show cause notices issued against the appellants expeditiously after providing them a hearing and passing reasoned orders within a reasonable period, preferably within three months from the conclusion of the hearing as per the guidelines laid down in Ramdular Singh vs. State of UP. The appellants were directed to appear before the Special Director on 2 January 2025 to set a schedule for the hearing.
The HC set aside the impugned order dated 9 March 2009 passed by the Special Director (Enforcement) due to inordinate and unexplained delay between the conclusion of arguments and pronouncement of the order. The matter was remanded to the Special Director (Enforcement) to dispose of the show cause notices issued against the appellants expeditiously after providing them a hearing and passing reasoned orders within a reasonable period, preferably within three months from the conclusion of the hearing as per the guidelines laid down in Ramdular Singh vs. State of UP. The appellants were directed to appear before the Special Director on 2 January 2025 to set a schedule for the hearing.
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