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 assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
HC held that the assessment reopening under SS147 was procedurally flawed. The AO failed to substantiate allegations of income escape by thoroughly examining disputed shipping bill evidence. The Assessee's contention of manual bill correction and non-involvement in alleged exports was not adequately addressed. Consequently, the SS148A(d) order was set aside, effectively nullifying the assessment reopening and upholding the Assessee's appeal without prejudice to potential future reassessment if concrete evidence emerges.
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