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...
A notice of demand under Section 156 requires an existing assessment or reassessment order fixing tax or arrears; absent such an antecedent order a demand notice is ultra vires and invalid. Where an original scrutiny assessment recorded nil liability, the revenue must invoke the reassessment/reopening procedure before creating fresh tax liability; issuing a demand years later on the same material without reopening under Section 147 amounts to an impermissible change of opinion. The impugned demand was therefore beyond jurisdiction and quashed.
A notice of demand under Section 156 requires an existing assessment or reassessment order fixing tax or arrears; absent such an antecedent order a demand notice is ultra vires and invalid. Where an original scrutiny assessment recorded nil liability, the revenue must invoke the reassessment/reopening procedure before creating fresh tax liability; issuing a demand years later on the same material without reopening under Section 147 amounts to an impermissible change of opinion. The impugned demand was therefore beyond jurisdiction and quashed.
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