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...
Petition seeking extension of previously granted benefits was remitted for fresh consideration because the issues raised implicate policy choices requiring inter-departmental consultation. The competent Ministries/authorities are directed to re-examine the petitioner's representation, give the petitioner an opportunity to be heard and to file additional documents, and to decide the matter in accordance with law expeditiously. The court refrained from expressing any view on the merits and kept all contentions open; the decision is to be taken promptly by the appropriate authorities after consultation.
Petition seeking extension of previously granted benefits was remitted for fresh consideration because the issues raised implicate policy choices requiring inter-departmental consultation. The competent Ministries/authorities are directed to re-examine the petitioner's representation, give the petitioner an opportunity to be heard and to file additional documents, and to decide the matter in accordance with law expeditiously. The court refrained from expressing any view on the merits and kept all contentions open; the decision is to be taken promptly by the appropriate authorities after consultation.
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