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 note addresses the legal sufficiency of an electronically uploaded assessment order and its summary carrying a Reference Number / Document Identification Number as proof of digital authentication; the Reference Number is treated as exclusively assigned to that order, supporting its validity. It also treats unexplained delay in approaching the court (laches) as fatal to relief where no explanation is offered; the procedural consequence is that challenges to such orders may be dismissed for laches when the petitioner accessed the portal but did not promptly seek judicial review.
The note addresses the legal sufficiency of an electronically uploaded assessment order and its summary carrying a Reference Number / Document Identification Number as proof of digital authentication; the Reference Number is treated as exclusively assigned to that order, supporting its validity. It also treats unexplained delay in approaching the court (laches) as fatal to relief where no explanation is offered; the procedural consequence is that challenges to such orders may be dismissed for laches when the petitioner accessed the portal but did not promptly seek judicial review.
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