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...
The HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
The HC upheld the impugned judgment in full and dismissed the appeal. The court found the revocation of the IPLOI (as amended) and subsequent invocation of the unconditional bank guarantee valid under the contractual terms: the Appellants defaulted, Clause 11 and the Addendum authorized termination and invocation, and the IPLOI prevailed over any RFP discrepancy. The Section 7 application filed by Respondent No.1 was not admitted before revocation and was ultimately dismissed as infructuous, so no actionable fraud was attributable to Respondent No.1; allegations of fraud were unpleaded and unproved. The court declined to restrain invocation of the unconditional BG absent egregious fraud or irretrievable injustice.
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