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...
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
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