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...
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
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