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 set aside ex-parte order due to violation of natural justice principles, specifically lack of proper service of pre-intimation notice and show-cause notice. Despite previous dismissal of petitioner's appeal as time-barred, the court adopted a justice-oriented approach. Recognizing petitioner's claim of bona fide reasons for non-participation, the court remitted the matter to the first respondent. The order directs a fresh consideration of the case, providing the petitioner an opportunity to submit a reply and contest the proceedings in accordance with legal principles.
HC set aside ex-parte order due to violation of natural justice principles, specifically lack of proper service of pre-intimation notice and show-cause notice. Despite previous dismissal of petitioner's appeal as time-barred, the court adopted a justice-oriented approach. Recognizing petitioner's claim of bona fide reasons for non-participation, the court remitted the matter to the first respondent. The order directs a fresh consideration of the case, providing the petitioner an opportunity to submit a reply and contest the proceedings in accordance with legal principles.
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