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 found the SCN uploaded in 'Additional Notices Tab' violated principles of natural justice, rendering the impugned order dated 5th August, 2024 invalid. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the SCN. Upon reply submission, the Authority must issue a personal hearing notice. The impugned order was set aside, and the petition was allowed through remand, ensuring procedural fairness and opportunity to be heard.
HC found the SCN uploaded in 'Additional Notices Tab' violated principles of natural justice, rendering the impugned order dated 5th August, 2024 invalid. The court remanded the matter back to the Adjudicating Authority, granting the Petitioner time until 10th July 2025 to file a reply to the SCN. Upon reply submission, the Authority must issue a personal hearing notice. The impugned order was set aside, and the petition was allowed through remand, ensuring procedural fairness and opportunity to be heard.
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