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...
Indefinite adjournment of a reserved appeal was held unjustified where a related appeal had been admitted but no stay of the admitted matter's operation existed; the tribunal, having reserved its order, could not simply post the case sine die without protecting the assessee's interests. The court found such post-reservation adjournment prejudicial, wasteful of resources and aggravating of grievance, set aside the indefinite postponement, declined to decide merits, and directed the tribunal to determine the appeal in accordance with law within a specified short period.
Indefinite adjournment of a reserved appeal was held unjustified where a related appeal had been admitted but no stay of the admitted matter's operation existed; the tribunal, having reserved its order, could not simply post the case sine die without protecting the assessee's interests. The court found such post-reservation adjournment prejudicial, wasteful of resources and aggravating of grievance, set aside the indefinite postponement, declined to decide merits, and directed the tribunal to determine the appeal in accordance with law within a specified short period.
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