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...
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The HC regularised the appellant's filing and condoned the delay in instituting the appeal. The matter is remitted to the appellate authority for adjudication on merits, with directions to proceed to hearing and dispose of the appeal in accordance with law and principles of natural justice. The court held that the requirement of pre-deposit may be met by debiting the electronic credit ledger where adequate credit exists; corresponding adjustments to electronic cash ledger may be effected as per statutory scheme. The provisional attachment of the appellant's bank account referred to in the impugned memo dated 06.08.2025 is ordered to be lifted forthwith. The appeal is closed.
The HC regularised the appellant's filing and condoned the delay in instituting the appeal. The matter is remitted to the appellate authority for adjudication on merits, with directions to proceed to hearing and dispose of the appeal in accordance with law and principles of natural justice. The court held that the requirement of pre-deposit may be met by debiting the electronic credit ledger where adequate credit exists; corresponding adjustments to electronic cash ledger may be effected as per statutory scheme. The provisional attachment of the appellant's bank account referred to in the impugned memo dated 06.08.2025 is ordered to be lifted forthwith. The appeal is closed.
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