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 allowed the petition challenging an impugned tax order, finding procedural irregularities in the original decision. The court determined that the order dated 27.04.2024 failed to meet statutory requirements under Section 75(6), specifically lacking substantive factual basis and reasoning. The HC quashed the previous orders and remanded the matter back to the Deputy Commissioner, directing a fresh review process. The Deputy Commissioner must provide the petitioner an opportunity to respond to the show cause notice within four weeks and subsequently issue a legally compliant order after affording proper hearing.
HC allowed the petition challenging an impugned tax order, finding procedural irregularities in the original decision. The court determined that the order dated 27.04.2024 failed to meet statutory requirements under Section 75(6), specifically lacking substantive factual basis and reasoning. The HC quashed the previous orders and remanded the matter back to the Deputy Commissioner, directing a fresh review process. The Deputy Commissioner must provide the petitioner an opportunity to respond to the show cause notice within four weeks and subsequently issue a legally compliant order after affording proper hearing.
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