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 a rectification order, finding procedural violations of natural justice. The court held that when a rectification application is rejected, the authority must provide reasoned order and opportunity of hearing to the applicant. The impugned order dated 28.03.2025 was set aside, directing the respondent to reconsider the rectification application afresh, provide notice to the petitioner, and pass appropriate orders in accordance with legal principles, particularly Section 161's third proviso mandating hearing when an order adversely affects an assessee.
HC allowed the petition challenging a rectification order, finding procedural violations of natural justice. The court held that when a rectification application is rejected, the authority must provide reasoned order and opportunity of hearing to the applicant. The impugned order dated 28.03.2025 was set aside, directing the respondent to reconsider the rectification application afresh, provide notice to the petitioner, and pass appropriate orders in accordance with legal principles, particularly Section 161's third proviso mandating hearing when an order adversely affects an assessee.
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