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...
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Note: It is a system-generated summary and is for quick reference only.
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