Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The HC dismissed the prayer for an interim stay and disposed of the petition by permitting the Petitioners to raise all permissible contentions before the Adjudicating Authority, including an application for deferment of the adjudication of the show-cause notice. The HC declined to adjudicate the allegation of delayed adjudication, directing that the Adjudicating Authority consider submissions and cited authorities relied upon by the Petitioners. The Petitioners are at liberty to seek deferment of proceedings in light of a related matter pending before the SC; no definitive determination was made on time-limitation grounds and the Adjudicating Authority shall proceed consistent with this direction.
The HC dismissed the prayer for an interim stay and disposed of the petition by permitting the Petitioners to raise all permissible contentions before the Adjudicating Authority, including an application for deferment of the adjudication of the show-cause notice. The HC declined to adjudicate the allegation of delayed adjudication, directing that the Adjudicating Authority consider submissions and cited authorities relied upon by the Petitioners. The Petitioners are at liberty to seek deferment of proceedings in light of a related matter pending before the SC; no definitive determination was made on time-limitation grounds and the Adjudicating Authority shall proceed consistent with this direction.
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