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 granted ad-interim relief to petitioners challenging retrospective application of penalty under Section 122(1A). The court found a prima facie case exists, noting the statutory provision was enacted on 1 January 2021 but sought to impose penalties for period prior to enforcement (July 2017 to December 2020). The court's interim order suggests substantial merit in petitioners' arguments, referencing a prior judicial precedent. Balance of convenience favors petitioners, indicating potential procedural irregularity in retrospective penalty imposition. Petition disposed with interim relief granted.
HC granted ad-interim relief to petitioners challenging retrospective application of penalty under Section 122(1A). The court found a prima facie case exists, noting the statutory provision was enacted on 1 January 2021 but sought to impose penalties for period prior to enforcement (July 2017 to December 2020). The court's interim order suggests substantial merit in petitioners' arguments, referencing a prior judicial precedent. Balance of convenience favors petitioners, indicating potential procedural irregularity in retrospective penalty imposition. Petition disposed with interim relief granted.
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