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...
HC held that the CIT(A)'s order directing deletion of additions relating to unexplained sundry creditors was valid. The AO's amendment under Section 154 was procedurally flawed as no notice was issued to the assessee, violating statutory requirements of Section 154(3). The court found a clear violation of natural justice principles by not providing an opportunity of hearing. Consequently, the order dated February 7, 2025 was set aside, and the authorities were directed to implement the previous order dated January 3, 2024 within four weeks, effectively reinstating the original appellate order deleting the contested additions.
HC held that the CIT(A)'s order directing deletion of additions relating to unexplained sundry creditors was valid. The AO's amendment under Section 154 was procedurally flawed as no notice was issued to the assessee, violating statutory requirements of Section 154(3). The court found a clear violation of natural justice principles by not providing an opportunity of hearing. Consequently, the order dated February 7, 2025 was set aside, and the authorities were directed to implement the previous order dated January 3, 2024 within four weeks, effectively reinstating the original appellate order deleting the contested additions.
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